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THAYER v. COMMISSIONER

Docket No. 7625-74.

36 T.C.M. 1504 (1977)

T.C. Memo. 1977-370

Robert H. Thayer and Virginia Thayer v. Commissioner.

United States Tax Court.

Filed October 25, 1977.

Attorney(s) appearing for the Case

John B. Jones, Jr., and Michael R. Levy, 888 Sixteenth St. N.W., Washington, D.C., for the petitioners. Frank J. Coyne, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year ended December 31, 1970, in the amount of $5,331.34. The single issue presented for decision is: What was the fair market value on January 30, 1969, of an open-space or scenic easement over Overlook Farm that petitioner Virginia Thayer donated to the Virginia Outdoors Foundation?1

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