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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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Last modified: May 25, 2011