- 13 -
everything required was not significant.10 Cf. Knight-Ridder
Newspapers v. United States, 743 F.2d 781, 793-797 (11th Cir.
1984).
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
distinguishable.
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