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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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Last modified: May 25, 2011