MEMORANDUM OPINION
DINAN, Special Trial Judge.
Respondent determined deficiencies in petitioner's Federal income taxes of $10,267 and $11,057, and penalties under section 6662(a) of $498.40 and $259.40, for the taxable years 1996 and 1997. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue.
The issues for decision are: (1) Whether petitioner is entitled to deductions for "business promotion...
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