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§ 10.1 VALUATION OF PROPERTYreceived, the person must indicate on the return that a statement has beenrequested and attach a copy of the request. Upon receipt of the statement, anamended or supplemental return must be filed with the statement of valueattached. If a person disagrees with a statement of value issued by the IRS, theperson may submit with the tax return additional information in support of adifferent value.A person may rely on a statement of value received from the IRS for an itemof art. A person may not, however, rely on a statement of value issued to anotherperson. Further, a person may not rely on a statement of value if the representationson which it was based are not accurate statements of the material facts.These procedures are a disappointment for those who were awaiting abroader process. They are confined to works of art, rather than other forms ofpersonal and real property; they do not allow for advance approval of valuations.The donor is committed to the transaction; once into the process, a withdrawalof a request for a valuation statement leads to notification of the IRSdistrict office, which will likely initiate an audit. Furthermore, the requirementsare so intricate that they are likely to discourage use of the procedures.Why would someone engage in this process? He, she, or it must alreadyhave a bona fide independent appraisal of the gift property and a completedappraisal summary. The donor is entitled to rely on the appraisal received. Onlythe most cautious will utilize this process in the income tax/charitable givingsetting.A tax return filed with an IRS statement of value and a charitable deductionbased on a higher valuation is likely to trigger an audit as well. As noted, the taxreturn can contain information in support of the selected value. But what new oradditional information will a taxpayer have at that point? Presumably, all relevantinformation will have been submitted as part of the request.The original point of conjuring up a procedure such as this was to minimizedisputes over property values in the tax context. Secondarily, it was intended torelieve judges (particularly those on the Tax Court) from the task of doing whatthey are not trained to do: be property appraisers. At this point, it is hard to seehow these procedures will help much in curbing quarrels over value, and freeingup judges for the tasks of making and interpreting law.(c) Valuation of Used VehiclesThe IRS published guidance as to valuation of used vehicles contributed to charitableorganizations, for purposes of determining the charitable deduction,including when it is permissible to rely on a pricing guide. 96 The agency, followinga recitation of the general rules, 97 stated that there “is no single correct wayto determine the fair market value of a car [or other vehicle]; any reasonablemethod may be used.”One method of determining the fair market value of a donated car or othervehicle, said the IRS, is by reference to an established used-car or other vehiclepricing guide. This guide, however, “establishes fair market value only if the96 Rev. Rul. 2002-67, 2002-47 I.R.B. 873.97 See § 10.1(a). 367