OPINION.
ATKINS, Judge:
The respondent determined a deficiency in income tax for the calendar year 1951, in the amount of $1,881.92. The only question for decision is whether the respondent erred in disallowing $8,758.41 of the amount of $9,887.55 claimed as a deduction under section 23 (u) of the Internal Revenue Code of 1939.
The facts were stipulated and the stipulation is incorporated herein by this reference.
The petitioners are...
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