Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' 1961 and 1962 Federal income taxes of $370.63 and $196.20, respectively. The sole issue is whether certain expenses incurred for educational study (including tuition, books, fees, supplies, meals, and transportation) are deductible as ordinary and necessary business expenses in the years in question.
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