Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar years 1970 and 1971 in the amounts of $2,606.36 and $3,785.45, respectively. The only issue for decision is whether petitioners are entitled to claim as a deduction the amounts of $12,114.26 and $14,255.87, or any parts thereof, in the years 1970 and 1971, respectively...
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