Memorandum Findings of Fact and Opinion
KORNER, Judge:
Respondent determined Federal income tax deficiencies against petitioner as follows:
Tax Year Ended Deficiency December 31, 1979.................. $ 901 December 31, 1980.................. 5,938
After concessions, the sole issue remaining for decision is whether petitioner is entitled to a deduction under section 404(a)(8)
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