Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined deficiencies in the Federal income taxes of the petitioners for the taxable years 1966 and 1967 in the amounts of $422.22 and $98.02, respectively.
The sole issue for our decision concerns the determination of the fair market value of certain property claimed as a charitable contribution under section 170 of the Internal Revenue Code of 1954.
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