Memorandum Opinion
QUEALY, Judge:
Respondent determined a deficiency of $794.00 in the income tax of petitioners for the taxable year ending December 31, 1972.
Because of concessions made by petitioners, there remains for decision whether certain fees withheld by a lending institution from loan proceeds are deductible by petitioners; and, if so, whether the fees are deductbile in the year the loan was made or ratably as the loan is repaid.
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