Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in Federal income tax against petitioner as follows:
Taxable Year Ended Deficiency July 31, 1972 ........... $16,320 July 31, 1973 ........... 16,320 July 31, 1974 ........... 16,320
The sole issue for our decision is whether the annual rental paid by petitioner...
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