Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency of $4,403 in petitioners' 1976 Federal income tax. After concessions, the issues for decision are:
1. Whether expenses incurred by petitioner David L. Stoddard in the maintenance and operation of a private aircraft are deductible educational expenses;
2. Whether petitioners are entitled to depreciation deductions with respect to such aircraft; and
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