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OSBORNE v. COMMISSIONER

Docket No. 15999-84.

87 T.C. 575 (1986)

ROBERT P. OSBORNE AND CAROL A. OSBORNE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 4, 1986.

Attorney(s) appearing for the Case

R. Kenneth Sparks, for the petitioners.

Benjamin A. de Luna, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $14,307 in petitioners' Federal income tax for 1981. The issue for decision is: Whether petitioners are entitled to a deduction for a charitable contribution under section 1701 for the installation and transfer of drainage facilities and easements to the City of Colorado Springs.

FINDINGS OF FACT

Petitioners Robert P. Osborne and Carol A. Osborne...

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