Memorandum Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1978 in the amount of $22,027.06. The issue for decision is whether petitioners completed a gift of 1,442 shares of stock in Babcock & Wilcox Company to eight charitities before the payment of cash for 710 of the shares pursuant to a tender offer and before accrual of the right to dividend income for the shares.
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