Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes for calendar years 1971, 1972, and 1973 in the amounts of $4,030.71, $119.56, and $6,478.74, respectively.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for decision (1) whether petitioners are entitled in 1971 to a section 38, I.R.C. 1954,
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