Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1972 in the amount of $6,915.60. One of respondent's adjustments has been conceded by petitioner so that the issues remaining for decision are: (1) Whether petitioner is entitled to a deduction under section 162(a), I.R.C. 1954,
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