OPINION
PIERCE, Judge:
The respondent determined a deficiency in the income taxes of the petitioners for the taxable calendar year 1960 in the amount of $4,442.74.
The sole issue for decision is whether section 642(h) of the 1954 Code and the regulations promulgated thereunder furnish warrant for the principal petitioner's deduction of $17,512 on his 1960 return, representing an alleged excess of deductions over gross income of the estate...
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