Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $1,983.92 for 1966 and $10,020.82 for 1967. At issue is the fair market value of a 21.36-acre tract of land, including improvements on part of the tract, donated by petitioners to the University of Tennessee on December 11, 1965.
Findings of Fact
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