Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined deficiencies in income taxes paid by petitioner for the following taxable years and in the following amounts:
Taxable Year Ended Deficiency December 31, 1971 ............. $53,812 December 31, 1972 ............. 50,379
Due to concessions by petitioner, the only issue for our decision is the allowability to petitioner of a deduction...
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