Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $7,829 in petitioners' Federal income taxes for 1979 (docket No. 7488-83) and deficiencies of $21,492.34 and $31,742.18 in petitioners' Federal income taxes for 1980 and 1981, respectively (docket No. 21999-83). In dispute is the value of certain gemstones donated by petitioners to the University of Richmond.
Findings of Fact
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