SECTION 12. ATTACHMENT OF

STATEMENT OF VALUE TO RETURN

.01 A copy of the Statement of Value, regardless of whether the taxpayer agrees with it, must be attached to and filed with the taxpayer’s income, estate, or gift tax return that reports the transfer of the item of art valued in the Statement of Value. However, if, prior to receiving a Statement of Value, the taxpayer files an income, estate, or gift tax return reporting the transfer of an item of art for which a Statement of Value was requested, the taxpayer must indicate on the return that a Statement of Value has been requested and attach a copy of the request to the return. Upon receipt of the Statement of Value, the taxpayer must file an amended income or gift tax return, or a supplemental estate tax return, with the Statement of Value attached.

.02 If a taxpayer disagrees with a Statement of Value issued by the Service, the taxpayer may submit with the tax return additional information in support of a different value.