Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years ending December 31, 1979, 1980 and 1981 in the amounts of $16,303.56, $28,136.53 and $19,064.60, respectively.
The single issue for decision is the fair market value on December 6, 1978, of a "scenic easement" over certain real estate in Rappahannock County, Virginia donated by petitioners to the Virginia...
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