MEMORANDUM OPINION
POWELL, Special Trial Judge.
Respondent determined a deficiency of $4,270 in petitioner's 2000 Federal income tax. The issues are whether petitioner is (1) entitled to a deduction under section 162 for educational expenses, (2) entitled to an exemption under Article 21 of the Convention for the Avoidance of Double Taxation, Oct. 13, 1972, U.S.-Belg., 23 U.S.T. (Part 3) 2687; (3) entitled to a charitable contribution deduction under section...
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