Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined a deficiency of $15,427 in petitioners' 1976 Federal income tax. After concessions, the issues for decision are (1) whether in substance, as well as in form, a limited partnership contributed stock in a corporation to an educational organization and (2) whether the contribution, however characterized, was complete in calendar year 1976.
Findings of Fact
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