Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the year 1982 in the amount of $2,400 as well as additions to tax for that year pursuant to sections 6653(a)(1) and 6653(a)(2) in the amount of $120 and 50 percent of the interest due on $2,400, respectively. The principal issue is the correctness of the Commissioner's disallowance of a $12,000 deduction for charitable contributions...
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