Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
Respondent determined deficiencies in petitioners' income tax of $248.23 for the taxable year 1961 and $245.73 for the taxable year 1962. The only issue for decision is whether petitioner Benjamin E. Adams was engaged in carrying on a trade or business as an artist so that certain expenses incurred during the taxable years are deductible as business expenses under section 162(a) of the Internal Revenue...
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