BONSAL, District Judge.
Mr. and Mrs. Sidney Rosen, the appellants, appeal from a decision of the Tax Court. The facts were stipulated to by the parties and need not be repeated in detail here. Mr. and Mrs. Rosen owned real property in Fall River, Massachusetts. On December 20, 1972, they made a gift of the property to the City of Fall River and claimed as a charitable deduction the value of the property, viz., $51,250, on their joint 1973 federal income tax return...
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