OPINION.
MULRONEY, Judge:
Respondent determined a deficiency in income tax for the year 1949 in the sum of $871.90. Harry Kahn, hereinafter called the petitioner, and Emma Y. Kahn, are husband and wife. They reside in New York City and they filed their joint income tax return for the year 1949 with the collector of internal revenue for the second district of New York.
The entire deficiency arises by reason of respondent's disallowance of a...
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