Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioner as follows:
Taxable Year Ended Deficiency ------------------------------------------------ July 31, 1972 ............ $20,702.86 December 31, 1972 ........ 5,261.63 December 31, 1973 ........ 19,286.84
Due to concessions, two issues remain for our decision:
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