Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the year 1964 in the amount of $2,697.34. He also determined an addition to tax for the late filing of petitioners' 1964 Federal income tax return in the amount of $74.06.
There are four issues to be decided. First, is whether petitioners' deduction of Lu Celia's pro rata share of a small business
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