Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency and penalty in the joint Federal income tax return of the petitioners for the taxable year 1971 in the amount of $2,015.87. Due to concessions by the parties, the issues for our decision are:
(1) Whether expenses incurred in connection with a proposed acquisition of a business are deductible under section 162 (a)(2), section 212(1), or section 165(c) (2...
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