Memorandum Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' income taxes in the amounts of $269.26 and $195.57 for the taxable years 1961 and 1962, respectively. Two issues are involved herein: (1) Was petitioner Lucile Sutherland engaged in the trade or business of producing and selling or leasing master records and (2) if she was so engaged, did she expend the sums of $1,596.32 in 1961 and $1,077.37 in 1962 in furtherance thereof...
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