Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $16,354.26 and $11,954.55 in petitioners' Federal income tax for 1978 and 1979, respectively. The sole issue for decision is whether petitioners are entitled to deductions for a charitable contribution pursuant to section 170.
Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the years in issue...
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