Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioners' Federal income taxes for the tax year 1976 in the amount of $7,416.53. After a concession by respondent, the issues for decision are whether airplane expenses paid by petitioner William F. Sherman, Jr., in the amount of $17,787.36 for 1976 constitute ordinary and necessary employee business expenses and whether the petitioner has met the substantiation...
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