Memorandum Findings of Fact and Opinion
COHEN, Judge:
In Docket No. 11095-83, respondent determined a deficiency of $20,183 in the Federal income taxes of petitioners Talebi for the taxable year 1979. In Docket No. 14538-83, respondent determined deficiencies of $20,258 and $11,189 in the Federal income taxes of petitioners Palantekin for the taxable years 1979 and 1980, respectively. In dispute is the value of certain gemstones donated by petitioners to...
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