Memorandum Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in income tax for 1972 in the amount of $47. The sole issue is whether the petitioner, Judith A. Sessions, a day-to-day substitute teacher, was gainfully employed on a substantially full-time basis during the year in issue within the scope of section 214 of the Internal Revenue Code of 1954 so that the petitioners are entitled to deduct child care expenses for such year.
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