Memorandum Findings of Fact and Opinion
FAY, Judge:
The respondent has determined a deficiency in petitioners' income tax for the calendar year 1970 in the amount of $508.04.
The sole issue presented for our decision is whether expenses incurred by petitioner Bernard W. Mugleston in the operation of an automobile between his residence and place of employment are deductible under section 162(a) of the Internal Revenue Code of 1954.
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