JOHN W. PECK, Circuit Judge.
In their income tax return for the calendar year 1961 petitioner (the singular is used because although this was a joint return, the issues herein considered arise solely from the husband's activities) claimed two charitable deductions which were disallowed by the respondent. Subsequent to such disallowance relief was sought in the Tax Court, and this appeal is from an order favorable to the Commissioner of Internal Revenue.
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