SECTION 6. APPRAISAL FOR

INCOME TAX CHARITABLE DEDUCTION PURPOSES

.01 An appraisal submitted to the Service by a taxpayer under section 5 of this revenue procedure must meet the requirements for a qualified appraisal under § 1.170A–13(c)(3)(i)– (iii), and must also include the following:

(1) a complete description of the item of art, including:

(a) the name of the artist or culture, (b) the title or subject matter, (c) the medium, such as oil on canvas, or watercolor on paper,

(d) the date created, (e) the size, (f) any marks, signatures, or labels on the item of art, on the back of the item of art, or affixed to the frame,

(g) the history (provenance) of the item, including proof of authenticity, if that information is available,

(h) a record of any exhibitions at which the item was displayed,

(i) any reference source citing the item, and

(j) the physical condition of the item; (2) a professional quality photograph of a size and quality fully showing the item, preferably an 8 - 10 inch color photograph or a color transparency not smaller than 4 - 5 inches; and

(3) the specific basis for the valuation.

.02 The appraisal must be made no earlier than 60 days prior to the date of the contribution of the item of art.

.03 Taxpayers are encouraged to include in the request any additional information that may affect the determination of the fair market value of the item of art.

.04 The requirements of section 6 of this revenue procedure must be met by Subchapter C corporations, even though

they would otherwise be exempt under § 1.170A–13(c)(2)(ii)(B)(3) from the appraisal requirements.