Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' income taxes for 1961 and 1962 in the amounts of $21,173.48 and $61,269.20, respectively. The sole issue presented for decision is whether expenses, in the amount of $25,930.10 in 1961 and $74,873.56 in 1962, incurred by petitioner in connection with the operation of his personally-owned airplane, are deductible under section 162
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