MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency in the amount of $2,754 in petitioner's Federal income tax for 1976. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions by both parties, we must decide the following issues: (1) Whether petitioner is...
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