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ROBERT E. BORMES ET AL., APPELLANTS, v. COMMISSIONER OF INTERNAL REVENUE, APPELLEE.

PER CURIAM.

This is an appeal by taxpayers from a decision of the Tax Court sustaining the Commissioner's valuation of real estate donated to a recognized charitable corporation. The decision of the Tax Court is supported by substantial evidence and is not clearly erroneous. We affirm upon the basis of the Tax Court's opinion reported at P-H Memo T.C. par. 74,065 (1974).

Affirmed.

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BORMES v. COMMISSIONER OF INTERNAL REVENUE
(Mar 21, 1975)