John T. and Linda L. Hewitt - Page 12

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          (respondent prevailed where no qualified appraisal was obtained).           
               Petitioners also seek to support their position by claiming            
          that there was a market which provided support for their use of             
          the average per-share price of the Jackson Hewitt stock.  This              
          position is without merit.  Given the amounts of the gifts in               
          this case, the exemption from the qualified appraisal                       
          requirements is statutorily limited to "publicly traded                     
          securities".  See sec. 155(a)(2)(A).  The parties have stipulated           
          that the Jackson Hewitt stock did not qualify as "publicly traded           
          securities".  See supra p. 4; see also Staff of Joint Comm. on              
          Taxation, General Explanation of the Revenue Provisions of the              
          Deficit Reduction Act of 1984, at 506 n.21 (J. Comm. Print 1985).           
          In this context, the fact that Bond v. Commissioner, 100 T.C. 32            
          (1993), involved blimps which were not as easily valued as the              
          Jackson Hewitt stock is irrelevant.                                         
               Petitioners' reliance on cases such as Taylor v.                       
          Commissioner, 67 T.C. 1071 (1977); Columbia Iron & Metal Co. v.             
          Commissioner, 61 T.C. 5 (1973); Sperapani v. Commissioner, 42               
          T.C. 308 (1964); Cary v. Commissioner, 41 T.C. 214 (1963), where            
          taxpayers prevailed on the basis of substantial compliance is               
          likewise without merit.  The key to those cases is that, as in              
          Bond v. Commissioner, supra, the taxpayers had provided most of             
          the information required, and the single defect in furnishing               

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