Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated March 5, 1982, respondent determined a deficiency in petitioners' Federal income tax of $3,361.97 for the taxable year ended December 31, 1978. Because of concessions made by the parties, the issues for decision are:
(1) Whether petitioners are entitled to a deduction for moving expenses under section 217
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