Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency of $4,269.77 in petitioner's income tax liability for the calendar year 1947. In his petition the taxpayer raised four issues, one of which was abandoned before the hearing. At the hearing petitioner stated three issues, one of which relating to a contribution to a charitable foundation, was later conceded by respondent in his brief. Thus there remain two issues:—
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