Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a deficiency in petitioners' 1969 Federal income tax of $12,025.19.
The two issues for decision are: (1) whether certain papers donated by petitioner Otto Kerner in 1968 to the Illinois State Historical Library were his personal property or the public property of the State of Illinois, and (2) the fair market value of these papers on the date of donation.
Petitioner...
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