Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1959 in the amount of $8,870.53 and an addition to tax under section 6651(a) of the Internal Revenue Code of 1954 for late filing of the return in the amount of $443.53.
The issues for decision are:
(1) Whether petitioners made a gift to a charitable foundation during the calendar year 1959 by transferring...
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