[Memorandum Opinion]
DAWSON, Judge:
In these consolidated cases respondent determined deficiencies in petitioner's Federal income taxes for the years 1976 and 1977 in the amounts of $7,773.05 and $13,581.50, respectively.
Concessions have been made by the respondent. At issue is whether the petitioner is entitled to deduct under section 212(1) or (2)
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