Dieter Stussy - Page 8

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          disclosed adequately the relevant facts of his treatment of the             
          charitable contribution carryovers in each of the years.  We also           
          believe that petitioner made a reasonable attempt to comply with            
          the provisions of the Code, and that he was not careless,                   
          reckless, or in intentional disregard of rules or regulations.              
          We hold for petitioner on this issue.                                       
               In reaching our holdings herein, we have considered all                
          arguments made by the parties for contrary holdings and, to the             
          extent not discussed above, find them to be irrelevant or without           
          merit.                                                                      
               To reflect a concession by respondent,                                 
                                                  Decision will be entered            
                                             under Rule 155.                          
























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