Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated January 22, 1981, respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1978 in the amount of $3,685.29. After concessions the issues for decision are: (1) whether the expense incurred by petitioners to hire persons to protect their personal residence in Ecuador is deductible pursuant to section 212, I.R.C. 1954; and (2) whether expenses...
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