Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $61,872 in petitioners' Federal income tax for the 1981 taxable year. After concessions, the issues for decision are whether petitioners are (1) entitled to a $98,000 charitable deduction claimed on their 1981 return, and (2) liable for the increased rate of interest pursuant to section 6621(c) (formerly section 6621(d)).
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