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BIALO v. COMMISSIONER

Docket No. 17358-83.

88 T.C. 1132 (1987)

WALTER BIALO AND MILDRED BIALO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 30, 1987.

Attorney(s) appearing for the Case

Randy B. Blaustein, for the petitioners.

Gregg M. Weiss, for the respondent.

OPINION

WRIGHT, Judge:

Respondent determined a deficiency of $59,077 in petitioners' Federal income tax for the taxable year ending August 31, 1978. The sole issue for decision is whether petitioners are entitled to a charitable contribution deduction with respect to certain stock in their closely held corporation pursuant to the provisions of sections 306(a) and 170(e)(1)(A).1

The facts have been stipulated and...

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