Memorandum Findings of Fact and Opinion
INGOLIA, Commissioner:
The respondent determined a deficiency in the petitioners' Federal income tax for the calendar year 1967 in the amount of $612.96. The only issue before the Court is whether travel expenses totaling $1,763.50 are deductible as "ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business", within the meaning of section 162(a) of the Code.
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