Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $10,975.22 in the petitioner's Federal income tax for 1977. He also determined an addition to tax of $548.76 under section 6653(a) of the Internal Revenue Code of 1954. The only issues to be decided are whether the petitioner is exempt from the Federal income tax because he executed a document in which he purported to donate his income to a church, and whether...
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