TANG, Circuit Judge:
The Commissioner of Internal Revenue ("Commissioner") determined that a charitable deduction made by John and Imelda Hansen was invalid. The Hansens appeal the Tax Court's decision upholding the Commissioner's deficiency assessment and additions to tax. The Hansens contend on appeal that: 1) they did not receive a fair trial; 2) the charitable deduction was valid; 3) the Commissioner erred in assessing a deficiency because a prior overpayment...
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