Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency of $5,403.15 in income taxes of the petitioners for 1959. A preliminary issue is whether respondent's deficiency determination was arbitrary and unreasonable. The primary issues in dispute are whether respondent correctly determined that certain business expenses in the total amount of $39,597.50 were not allowable as deductions in computing the net ordinary income of...
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