MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
Petitioners Ian G. and Tonya A. Koblick (individually referred to as Mr. Koblick and Mrs. Koblick, respectively) challenge respondent's income tax deficiency determination for 1998 and 1999 which is based upon the disallowance of charitable deductions that were carried forward from a 1994 contribution of 45 percent of the outstanding stock in Sealodge International, Inc. (Sealodge) to Maine Resources...
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