Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1977, 1978, and 1979 in the amounts of $5,563.33, $3,039.86, and $4,437.70, respectively. After concessions, the only issue remaining for decision is whether the expenses of owning, operating, and maintaining an airplane are deductible by petitioners under section 212.
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