Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the fiscal year ended October 31, 1972 of $4,821 and for the fiscal year ended December 31, 1972 of $1,221 and a penalty pursuant to section 6651(a)
Due to the concessions the only issue presented for our consideration is whether a deduction...
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