John T. and Linda L. Hewitt - Page 14

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          of the substantial compliance principle but an exemption from the           
          clear requirement of the statute and regulations in a situation             
          where there is no overvaluation of the charitable contribution.             
          We are not prepared to follow that path to decision.                        
               We hold that petitioners are not entitled to deduct amounts            
          in excess of those allowed by respondent for the contributions of           
          Jackson Hewitt stock.  See supra note 7.                                    
               To take into account the concessions of the parties,                   
                                        Decision will be entered                      
                                   under Rule 155.                                    

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