SIMPSON, Judge:
The respondent determined a deficiency of $486.82 in the income tax of the petitioners for the taxable year 1965. The issue for decision is whether a real estate broker may deduct $2,000 which he paid as an initiation fee to the Homeowners Multiple Listing Service, Inc., as an ordinary and necessary business expense, or as an expense for the production of income.
FINDINGS OF FACT
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