Memorandum Findings of Fact and Opinion
CALDWELL, Commissioner:
Respondent determined a deficiency in petitioners' income taxes for 1967 in the amount of $163. The sole issue presented for decision is whether petitioner is entitled to a deduction for amounts paid to a private club of which he was a member, as an ordinary and necessary business expense, under section 162(a) and section 274 of the Internal Revenue Code of 1954.
Findings of Fact
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