Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a deficiency of $1,805.35 in petitioners' 1973 income tax. Petitioners herein dispute respondent's disallowance of their miscellaneous deduction of $9,933.42. Respondent has moved for judgment on the pleadings under Rule 120, Tax Court Rules of Practice and Procedure.
Petitioners resided in New York City, New York at the time...
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