Memorandum Findings of Fact and Opinion
SWIFT, Judge:
By statutory notice of deficiency dated July 18, 1981, respondent determined deficiencies in petitioners' Federal income tax liabilities as follows:
Year Deficiency 1977 .......... $18,207 1978 .......... 18,283 1979 .......... 12,887
After concessions by the parties, the only issue for decision is whether petitioners are entitled to deduct the...
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