Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in the Federal income tax return of the petitioner for the taxable year 1969 in the amount of $4,684.63. Due to agreements and concessions by the parties, the issue for our decision is whether the petitioner is entitled to an interest deduction of $2,948.80 for amounts paid to the New York City Collector during the taxable year 1969 pursuant to section 163(a).
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