Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' income tax in the amounts of $37,307.94 and $35,415.23 for the taxable years 1966 and 1967, respectively. The sole issue presented for decision is the valuation of a painting which was the subject of a charitable contribution.
Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits...
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