Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
On October 3, 1985, respondent issued a statutory notice of deficiency to petitioners for the taxable year ended December 31, 1981, having determined a deficiency in the amount of $59,512.59. The sole issue for decision is the fair market value of a facade servitude donated to the Preservation Alliance of New Orleans.
Findings of Fact
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