Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
Respondent determined a deficiency in petitioner's 1984 and 1985 Federal income tax in the amounts of $2,623.60 and $2,151, respectively. The issues for decision are (1) whether Thomas H. McFall (petitioner) is entitled to deductions under section 170 for charitable contributions for taxable years 1984 and 1985, and (2) whether additions to tax pursuant to...
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