Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners' Federal income tax for the calendar years 1975 and 1976 in the respective amounts of $4,105.07 and $13,425.55. Concessions having been made, the sole issue for decision is the fair market value of certain patents contributed by petitioners to the University of Santa Clara in 1974, 1975, and 1976.
Findings...
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