Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined a deficiency in petitioners' 1981 Federal income tax in the amount of $4,669. The issues presented for consideration are: (1) whether a charitable contribution deduction of $7,000 is available for the value of petitioners' services to Health Advocates, Inc., Plus Group Homes, Inc., and the New York State Council of Organizations for the Handicapped or, alternatively, whether petitioners...
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