Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent has determined deficiencies in petitioner's Federal income tax for the taxable years 1970 and 1971 in the amounts of $1,059.10 and $545.55, respectively. Due to concessions by the parties, the issues for our determination are: (1) Whether petitioner is entitled to deduct as a business expense, pursuant to section 162(a)(2),
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