Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1965 in the amount of $169.06.
The issues for decision are whether petitioner Ben (Bong) H. Kim is entitled to deduct $764 or any part thereof as an ordinary and necessary business expense for education and to deduct $200 or any part thereof as an expenditure for the production and collection of income.
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