Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in the petitioners' income tax for the calendar year 1955 in the amount of $44,608.79. The parties have disposed of certain issues raised in the pleadings. The remaining issues for decision are:
(1) Whether petitioners are entitled to deduct, within the meaning of section 163(a) of the Internal Revenue Code of 1954,
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