Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $2,410.43 and $5,128.28 for the calendar years 1966 and 1967, respectively.
The issue for decision is the fair market value of a 5 percent working interest in certain oil and gas leases donated by petitioners to a tax exempt, educational institution.
Findings of Fact
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