Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $2,472.60 in petitioners' Federal income tax for 1973.
Concessions having been made, we must decide the extent to which, if any, petitioners are entitled to deduct certain fees and related expenses paid by Wade H. Snell, Jr., in connection with his becoming a member of Lloyd's of London.
Findings of Fact
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