Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined deficiencies in the Federal income taxes of the petitioner of $1,802.38 for the year 1971 and $1,336.62 for the year 1972. Certain issues have been conceded by the petitioner, and the issue remaining for decision is whether section 152(b)(3) of the Internal Revenue Code of 1954,
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