HALL, Judge:
Respondent determined a deficiency of $2,620.69 in petitioners' income tax for 1973. Due to concessions by both parties, the sole issue for decision is the tax treatment of a sewer tap fee paid by petitioners to the City of Brentwood, Tenn., in 1973. Specifically, the questions presented are:
(1) Whether petitioners' sewer tap fee paid to the City of Brentwood is a nondeductible tax for local improvements within the meaning of section 164...
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