Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for taxable years ending December 31, 1979, 1980 and 1981 in the amounts of $29,095.59, $39,811.23, and $27,837.71, respectively.
The single issue for decision is: what was the fair market value on December 17, 1979, of a "scenic easement" over certain real estate in Rappahannock County, Virginia, donated by petitioners to...
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