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ORCHARD v. COMMISSIONER

Docket No. 7290-72.

34 T.C.M. 205 (1975)

T.C. Memo. 1975-31

Robert H. Orchard and Lois N. Orchard v. Commissioner.

United States Tax Court.

Filed February 24, 1975.

Attorney(s) appearing for the Case

Harold G. Blatt and Juan D. Keller, for the petitioners. James E. Cannon, for the respondent.

Memorandum Opinion

WILBUR, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the years 1969 and 1970 in the amounts of $14,842.00 and $26,304.13, respectively. Due to concessions made by the parties, the only issues remaining for decision are:

(1) Whether the magnetic tape copies of opera recordings donated to various universities were contributions of property alone, or were contributions of property and services...

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