Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in income tax due from petitioners for the taxable year 1974 in the amount of $5,988.14. As a result of agreement by the parties, the only issue remaining for decision relates to the deductibility as interest for the taxable year 1974 of two checks totaling $8,000 made out by the petitioner to the Mattei-Nappi Pension Fund.
Findings of Fact
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