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B. Substantial Compliance
Having failed to strictly comply with the substantiation
requirements, petitioners assert they are entitled to a deduction
because they substantially complied with the regulations.
The doctrine of substantial compliance is designed to avoid
hardship in cases where a party does all that can reasonably be
expected of him, but he nonetheless has failed to comply with the
requirements of a statutory provision. Estate of Chamberlain v.
Commissioner, T.C. Memo. 1999-181, affd. 9 Fed. Appx. 713 (9th
Cir. 2001). This Court has applied the substantial compliance
doctrine and excused taxpayers from strict compliance with
procedural regulatory requirements, provided that the taxpayers
substantially complied by fulfilling the essential statutory
purpose. Id. (and cases cited therein).
Petitioners rely primarily on Bond v. Commissioner, 100 T.C.
32 (1993). In Bond, the taxpayers contributed property that was
appraised by a qualified appraiser within the specified period.
The appraiser signed the Form 8283 and included on it nearly all
of the information required in a qualified appraisal. The
appraiser did not prepare a separate appraisal document, however,
nor did he list his qualifications on the Form 8283. Id. at 34.
Shortly after the Commissioner began examining the taxpayers’ tax
return, the appraiser provided the Government with a letter
describing his qualifications in detail. Id. at 34-35. The
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