Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
1965 ....... $ 92,493.07 1966 ....... 148,202.85 1967 ....... 85,964.85 1968 ....... 4,750.22
As a result of lengthy negotiations, the parties have settled all issues by stipulation save one — the fair market value of a painting donated by petitioner...
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