United States Tax Court.
[Memorandum Findings of Fact and Opinion]
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's income taxes as follows:
Taxable year Deficiency 1961 ............ $ 7,249.65 1962 ............ 11,390.83 1963 ............ 12,719.40
Concessions on both sides leave only one issue for decision: Is petitioner entitled to a deduction under section 170
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