Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,423.32 for their taxable year ending December 31, 1973.
The issues presented for our decision are whether the transfer in 1973 by petitioners of 3.64 acres of land to the Land Conservation Trust of the Town of Madison, Conn., as a requirement for zoning approval of petitioners' subdivision plan entitled...
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