Whether equitable tolling may extend substantiation evidence gathering deadlines under I.R.C. § 170(f)(12)

QUESTIONS PRESENTED 1. Whether equitable tolling may extend substantiation evidence gathering deadlines under I.R.C. § 170(f)(12). 2. Whether Congress lacks the power to delegate unbridled discretion to the Commissioner to refuse to promulgate regulations which provide equitable relief from filing deadlines in appropriate cases. 3. Whether in a statutory scheme conflicting provisions must be construed and applied, if possible, so that both competing purposes can be realized. 4. Whether Petitioner was entitled to a hardship exemption under I.R.C. § 170(f)(11). 5. Whether the Petitioner Izen was entitled to summary judgment because the Commissioner failed to present controverting evidence supporting his claim that a charitable deduction was never made and that the charitable deduction had no value.