John T. and Linda L. Hewitt - Page 13

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          everything required was not significant.10  Cf. Knight-Ridder               
          Newspapers v. United States, 743 F.2d 781, 793-797 (11th Cir.               
               Moreover, it is clear that the principal objective of                  
          section 155 was to provide a mechanism whereby respondent would             
          obtain sufficient return information in support of the claimed              
          valuation of charitable contributions of property to enable                 
          respondent to deal more effectively with the prevalent use of               
          overvaluations.  See S. Comm. on Finance, Deficit Reduction Act             
          of 1984, Explanation of Provisions Approved by the Committee on             
          March 21, 1984, S. Prt. 98-169, vol. I, at 444-445 (S. Comm.                
          Print 1984); Staff of Joint Comm. on Taxation, General                      
          Explanation of the Revenue Provisions of the Deficit Reduction              
          Act of 1984 (J. Comm. Print 1985); cf. Atlantic Veneer Corp. v.             
          Commissioner, 85 T.C. 1075, 1084 (1985), affd. 812 F.2d 158 (4th            
          Cir. 1987).  Such need exists even though in a particular case,             
          such as this, it turns out that the taxpayer's deduction was in             
          fact based on the fair market value of the property.  This                  
          happenstance is insufficient to constitute substantial compliance           
          with a statutory condition to obtaining the claimed deduction.              
          As we see it, what petitioners are seeking is not the application           

               10  We recognize that Cary v. Commissioner, 41 T.C. 214                
          (1963), may not fall within this description, but it is clear               
          that we were persuaded that the omission involved therein was               
          solely through inadvertence.  Petitioners' failure to comply goes           
          far beyond inadvertence.  Cary is therefore clearly                         

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