§1213

1213(a)(1), 120 Stat. at 1075-1076. Because petitioners made their contribution in 2006, the year in which the PPA was enacted, sec. 170(h)(4)(B)(iii) does not apply in this case.

1213(e) of the Taxpayer Relief Act of 1997, Pub. L. 105-34, 111 Stat. 788, 1001. The lease in the instant case was entered into on or about August 21, 1995. Thus, section 110 does not apply in the instant case. Secondly, even if the Lease were subject to section 110, it would not apply in the instant case given the nature of the parties’ dispu

Petitioners' Failure To Satisfy the Appraisal-Inclusion Requirement Section 170(h)(4)(B)(iii)(I) provides that a taxpayer donor who contributes a use restriction (such as the facade easement) encumbering a certified historic structure in a registered historic district (such as the Lakewood house) must include with his tax return for the year ofthe contribution a qualified appraisal.