Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in income tax against the petitioners for the year 1975 in the amount of $4,196. Certain concessions having been made by the parties, the issues remaining for our consideration are (1) whether the Commissioner's determination in the statutory notice of deficiency was arbitrary and excessive, (2) whether petitioners are entitled to a deduction for employee business expenses...
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