Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies of $6,917 and $2,504, respectively, in petitioners' 1980 and 1981 Federal income taxes. The sole issue to be decided is whether respondent erred in disallowing claimed miscellaneous itemized deductions and determining petitioners were instead entitled to deductions under sections 165 and 166
Findings of Fact
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