OPINION
PER CURIAM:
The issue before the court in this action for recovery of federal income taxes is the fair market value of a figure painting by Jean Baptiste Camille Corot, "La Meditation," during the 2-year period 1967-68, in which the plaintiffs donated undivided interests in the painting to the University of Houston. Both parties appeal from the decision of Senior Trial Judge Mastin G. White that the value of the painting was $160,000.
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