Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies of $211.54 and $2,004.87 in the income tax of petitioners for 1964 and 1965, respectively. Several issues have been settled by the parties; however, the following issues remain for decision:
(1) Whether respondent correctly disallowed any charitable contribution deduction in excess of $1,000 attributable to petitioners' donation of an undivided one-half interest...
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