Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the income tax liability of petitioner for the taxable years 1966 and 1967, as follows:
Year Deficiency 1966 ............ $2,625.33 1967 ............ 2,895.33
The issue is whether the petitioner is entitled to an ordinary deduction under section 215,
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