Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent has determined a deficiency in income tax for the year 1945 in the amount of $997.92. The petitioner contends that there is no deficiency and that he has overpaid tax in the amount of $1,592.82. The petitioner contends that the respondent erred in disallowing deduction in the amount of $1,831.66 which was deducted as a business expense. In his petition,
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