Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1960 in the amount of $1,550.15.
The issues for decision are:
(1) Whether a subsistence allowance in the amount of $2,886.80 paid to James A. Drinko by his employer and included in income should be offset by a deduction in the same amount claimed for expenses incurred in connection with employment and
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