Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in the individual income taxes of petitioners for the calendar years 1979, 1980 and 1981 in the respective amounts of $5,835, $10,589.40 and $12,651.80. The sole issue which we must decide is the deductibility of certain amounts claimed by petitioners as charitable contributions in their joint returns, and disallowed by respondent under section 170.
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