Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner Adolph Posner for taxable year 1969 and of petitioners Adolph and Florence Posner for taxable year 1970 in the amounts of $4,012.21 and $2,419.83, respectively. The only issue for decision is the valuation of a painting for purposes of determining the amount allowable to petitioners as a charitable deduction under section 170...
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