Comment on FR Doc # N/A

In proposed Reg 1.170A-16(c) and (d), the substantiation requirements include a contemporaneous written acknowledgement and a Form 8283. Clear guidance should be provided as to whether the Form 8283 can constitute the written acknowledgement because the Form 8283 is signed by the Donee and includes the same information required for the acknowledgment. I know many preparers believe the Form 8283 is adequate for the acknowledgment, but have had IRS agents challenge a donation supported by a Form 8283 but where the Donee did not deliver a separate acknowledgement. William Frey