OPINION
DAWSON, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the taxable years 1961 and 1962 in the amounts of $954.75 and $1,135.52, respectively. The sole issue for decision is whether petitioners, who gave to certain charitable organizations negotiable warehouse receipts evidencing sharecrop rents, must include in their gross income the amounts received by the donees...
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