Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency of $194.40 in petitioners' income tax for the taxable year 1974.
The only issue for our decision is whether petitioners are entitled to a deduction for child care expenses incurred on behalf of their daughter. Resolution of this issue depends upon whether petitioner-husband was gainfully employed for purposes of section 214
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