Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6653(a)1 1980 .... $3,344 $172.15 1981 .... 3,413 170.65
The issues for our decision are: (1) whether petitioners are entitled to a charitable...
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