Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the years 1971 and 1972 in the amounts of $11,377 and $65,252, respectively. Certain issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision whether petitioner properly deducted under section 162(a) or section 212, I.R.C. 1954,
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