Memorandum Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioner's Federal income tax:
Taxable year Deficiency 1977 .......... $2,857.14 1978 .......... 483.00
After concessions by petitioner, the issue for decision is whether petitioner is entitled to a deduction for expenses under section 162(a) or section 212(2)
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