Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax in the amounts of $1,144.28 and $657.88 for the taxable years 1975 and 1976, respectively.
After concessions by petitioners the issues remaining are: (1) Whether petitioner Thomas C. Banks may deduct under section 162(a):
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