Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined a deficiency in petitioners' 1981 Federal income tax of $7,512.
After concessions, the sole issue for decision is whether petitioners are entitled to a charitable contribution deduction in excess of $5,245 for their donation of a collection of mathematical journals to the Mathematical Sciences Research Institute, a tax-exempt charitable organization.
While fully...
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