STERRETT, Judge:
For the taxable years ended June 30, 1966, and June 30, 1967, the respondent determined deficiencies in the petitioners' Federal income taxes of $3,371.56 and $1,226.84, respectively. Due to concessions by the petitioners the sole issue remaining for decision is whether the provisions of section 267(a)(2) of the Internal Revenue Code of 1954
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