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RECEIPT, RECORDKEEPING, AND REPORTING REQUIREMENTSare not required to attach a copy of the qualified appraisal of the property to theirreturn: they are required only to obtain an appraisal and attach the appraisalsummary. 113 (Moreover, the donors did not timely procure a complete appraisalsummary, though they were not charged with that offense.) Nonetheless, thisopinion is helpful because the court held that these requirements are not mandatorybut merely directory.In the case, a married couple donated two thermal airships (blimps) to acharitable foundation. They obtained the services of a qualified appraiser, whotimely determined the value of the property. The appraiser completed theappraisal summary, prepared the requisite certification, and signed the appraisalsummary form. The donors claimed a charitable deduction for the appraisedamount and attached a copy of the appraisal summary form to their return. Onaudit, the IRS disallowed the deduction because the donors did not attach totheir tax return a qualified appraisal of the blimps. The donors, in the Tax Court,in effect pleaded for some equity, arguing that they had substantially compliedwith the substantiation requirements and thus remained entitled to the charitablededuction. The court reviewed the law embodied in the doctrine of substantialcompliance and agreed with the donors.In applying this doctrine, courts look at whether the government’s requirementsrelate to the substance or essence of the statute. If so, strict adherence toall statutory and regulatory requirements is necessary. Otherwise, when therequirements are procedural or directory, the law may be satisfied by substantialcompliance. The court held that the substantiation requirements “do not relateto the substance or essence of whether or not a charitable contribution was actuallymade.” 114 Thus, it found that the requirement that certain documentation beattached to the return is directory, not mandatory.The court noted that the gift was indeed made, that there was an appraisalby a qualified appraiser, and that the charitable donee qualified as such. All ofthis information appeared in the appraisal summary form (except for the qualificationsof the appraiser, which were supplied by letter during the audit). 115Therefore, the court concluded that the donors “met all of the elementsrequired to establish the substance or essence of a charitable contribution, butmerely failed to obtain and attach to their return a separate written appraisalcontaining the information specified in . . . [the IRS’s] regulations even thoughsubstantially all of the specified information except the qualifications of theappraiser appeared in the [appraisal summary] . . . attached to the return.” 116The court added: “The denial of a charitable deduction under these circumstanceswould constitute a sanction which is not warranted or justified.” 117Thus, even though this opinion contains a material misstatement of the law, it113 See § 21.2(b), text accompanied by note 83.114 Bond v. Commissioner, 100 T.C. 32, 41 (1993).115 This is where the donors made their mistake. Their qualified appraisal did not timely contain the qualificationsof the appraiser (Reg. § 1.170A-13(c)(3)(ii)(F)) and thus it was incomplete. But they were not charged withthis violation.116 Bond v. Commissioner, 100 T.C. 32, 42 (1993).117 Id. 600