OPINION.
MURDOCK, Judge:
The only issue for decision is whether the Commissioner erred in disallowing a deduction of $111,925.95 claimed under section 23 (o) of the Internal Revenue Code of 1939 as a contribution to a church. The facts have been presented by a stipulation which is adopted as the findings of fact.
The petitioners, husband and wife, filed a joint income tax return for 1949 with the collector of internal revenue at Austin, Texas...
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