Bruce and Jeanne Korson, et al. - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  Respondent determined deficiencies in                 
          income tax and additions to tax as follows:                                 
                                                       Additions to Tax               
                                       Year  Deficiency    Sec. 6651(a)(1)           
                                                                                     
          Bruce and Jean Korson         1991   $10,000           $396                 
          Armin B. Allen                1991     5,484           --                   
          John H. and Susan N. Allen    1991     9,415           --                   
          Petitioners have assigned error to respondent’s determinations              
          and, in addition, have claimed overpayments in tax.                         
               Petitioners Bruce and Jeanne Korson concede the section                
          6651(a)(1) addition to tax, and the only other issue for                    
          decision, common to all petitioners, is the fair market value of            
          certain property contributed to charity.                                    
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
          Introduction                                                                
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, with accompanying exhibits, is                    
          incorporated herein by this reference.  At the time the petitions           
          in these cases were filed, petitioners Bruce and Jeanne Korson              
          resided in Oyster Bay Cove, New York, petitioner Armin B. Allen             





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