Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioner's income tax in the amounts of $1,561.21 for 1976 and $1,177.00 for 1977. The deficiencies resulted from the disallowance of expenses in excess of rental income claimed by the petitioner in connection with property petitioner rented to his parents. Due to concessions by the petitioner, the sole issue for our decision is whether the deduction of petitioner...
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