Memorandum Findings of Fact and Opinion
GUSSIS, Commissioner:
Respondent determined a deficiency in the petitioners' Federal income tax for 1968 in the amount of $153.22. The issue is whether petitioners are entitled to a charitable contribution deduction under section 170 of the Internal Revenue Code of 1954 for payments made by petitioners in 1968 to the Whitinsville Society for Christian Instruction in excess of the amount allowed by respondent.
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