Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
Respondent determined a deficiency in petitioner's 1982 Federal income tax liability in the amount of $5,450. Petitioner filed a timely petition on October 21, 1985. At the time that the petition was filed, petitioner was a resident of New Jersey. The issue before the Court is whether petitioner is entitled to a deduction under section 215
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