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timing requirements, those provisions are inapplicable to
petitioners’ case. Nothing in DEFRA section 155 indicates that
taxpayers are otherwise allowed to cure a failure to comply with
the timing requirements.
B. Equitable Considerations
Petitioners argue that denying them a deduction would be
inequitable. Petitioners contend they donated something of value
to DALPF and should not be denied a deduction for failing to
comply with an arbitrary deadline.
We note, first, that we are not a court of equity and do not
possess general equitable powers. Stovall v. Commissioner, 101
T.C. 140, 149-150 (1993); Knight v. Commissioner, T.C. Memo.
1998-107. “‘There is no general judicial power to relieve from
deadlines fixed by legislatures’”. Dirks v. Commissioner, T.C.
Memo. 2004-138 (quoting Prussner v. United States, 896 F.2d 218,
223 (7th Cir. 1990)), affd. 154 Fed. Appx. 614 (9th Cir. 2005).
Second, “‘deadlines, like statutes of limitations,
necessarily operate harshly and arbitrarily with respect to
individuals who fall just on the other side of them’”. Dirks v.
Commissioner, supra (quoting United States v. Locke, 471 U.S. 84,
101 (1985)). Nevertheless, “‘The legal system lives on fixed
deadlines; their occasional harshness is redeemed by the clarity
which they impart to legal obligation.’” Id. (quoting Prussner
v. United States, supra at 222).
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