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HOWARD v. COMMISSIONER

Docket No. 4939-78.

41 T.C.M. 1554 (1981)

T.C. Memo. 1981-250

Jack R. and Eleanor Harris Howard v. Commissioner.

United States Tax Court.

Filed May 21, 1981.

Attorney(s) appearing for the Case

Richard Katcher, 1956 Union Commerce Bldg., Cleveland, Ohio, for the petitioners. Tracy L. Rich, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1973 and 1974 in the amounts of $5,441 and $6,510, respectively. Due to concessions by petitioners, the remaining issues for our decision are:

(1) Whether club dues and expenses are deductible as ordinary and necessary business expenses under section 162,1 and if so,

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