Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1976 in the amount of $3,566.08. The issues are (1) whether the petitioners adequately substantiated their claimed contribution deductions; (2) if the claims were adequately substantiated, is the Church of the Brothers a separate and distinct entity from the Universal Life Church, Inc., of Modesto, California...
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