Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies in petitioner's income tax as follows:
Year Deficiency 1973 ............ $ 98,221 1974 ............ 104,567 1975 ............ 124,146
These deficiencies result from the disallowance of carryovers of charitable deductions from a contribution made in 1970.
The only issue with which we are presented is the determination...
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