Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years ended October 31, 1961, and October 31, 1963, in the respective amounts of $95,750.32 and $3,497.93. Certain issues having been conceded, the only issue remaining for decision is the fair market value of property contributed by petitioner to a charitable organization, in the taxable year ended October 31, 1961. Such value will...
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