Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in petitioners' 1959 income tax in the amount of $2,567.82. Petitioners agreed to all adjustments other than the issue that is now presented as to whether they are entitled to a deduction under sections 162 or 165 of the Internal Revenue Code of 1954,1 for amounts paid to George Summerfield during 1959.
Findings of Fact
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