Memorandum Opinion
STERRETT, Judge:
By notice of deficiency dated September 24, 1980, respondent determined a deficiency of $499 in petitioners' Federal income tax for the taxable year 1977. The sole issue for decision is whether certain expenses incurred by petitioner Robert M. Allen were ordinary and necessary expenses incurred in his trade or business.
The facts have been fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure...
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