Memorandum Findings of Fact and Opinion
PARKER, Judge:
By a statutory notice of deficiency dated May 4, 1982, respondent determined a deficiency in and addition to petitioners' 1980 Federal income tax as follows:
Section 6653(a) Deficiency Addition1 $2,102 $105
The issues for decision are (1) whether petitioners are entitled to a charitable contribution...
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