Memorandum Opinion
DRENNEN, Judge:
These cases involved primarily the value of certain interests in a large collection of antique stereoscopic negative glass plates and related material, known as the Keystone-Mast Collection, which were donated by the petitioners to the University of California at Riverside (UCR) in 1977 and 1981. On their income tax returns for those years petitioners claimed a value of $1,427,253 for the entire collection and deducted...
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