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Rose, an avid art enthusiast, visited many museums and art collections. Over time, Rose became quite the art collector, with various beautiful paintings proudly displayed in her home. She found that she was running out of wall space. Rose wanted to continue supporting the arts. She decided it was the right time to donate her Impressionist art collection to her favorite charity. She had owned all of the paintings for over a year. Later that same year, she decided to contribute her Realist art collection, which she acquired in the early 1980's, to the same charity. In response to an end of the year campaign conducted by her favorite charity, Rose decided to donate a photograph collection she purchased some time ago.
When Rose inquired about an appraisal, she was informed that she would need two qualified appraisals. One appraisal valued the Impressionist and Realist art collections and the other valued the photographs. The appraisal of the paintings was permissible because all of the art in each collection was comprised of paintings and thus satisfied the Service's definition of "similar items of property." Reg. 1.170A-13(c)(7)(iii). The photographs did not satisfy the meaning of the "same generic category or type," which is why she was required to obtain a separate appraisal for that donation.
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