United States Tax Court.
Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioner's income tax for 1974-1976 in the following amounts:
Year Deficiency 1974 ................ $ 6,033.65 1975 ................ 17,689.04 1976 ................ 5,434.20
The issues for decision are: (1) whether petitioner is entitled to a section 162(a)(1)
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