The Commissioner determined a deficiency of $661.10 in the income tax of Michael P. and Elizabeth B. Nammack for the calendar year 1965. The only issue for decision is whether petitioners are entitled to a deduction for child care expenses under either section 162, I.R.C. 1954, or section 214, I.R.C. 1954. Resolution of that issue depends upon the constitutionality of section 214(b) under the due process clause of the fifth amendment to the United States Constitution.
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