Memorandum Findings of Fact and Opinion
STERRETT, Judge:
In a notice of deficiency, dated April 1, 1980, respondent determined a deficiency in petitioners' Federal income tax of $12,176.96 for the taxable year 1977. After concessions by the parties, the primary issues remaining for decision are:
(1) Whether petitioners are entitled to deduct under section 162 or section 212, I.R.C. 1954, certain expenditures made with respect to their residence,...
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