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EDWIN L. SESSIONS and JUDITH A. SESSIONS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sessions v. Commissioner

Docket No. 3887-74.

United States Tax Court

T.C. Memo 1976-65; 1976 Tax Ct. Memo LEXIS 338; 35 T.C.M. (CCH) 290; T.C.M. (RIA) 760065;

March 8, 1976, Filed

*338 Randall E. Ferguson, for the petitioners.

Gregory M. Hansen, for the respondent.

FORRESTER

MEMORANDUM OPINION

FORRESTER, Judge: Respondent has determined a deficiency in income tax for 1972 in the amount of $47. The sole issue is whether the petitioner, Judith A. Sessions, a day-to-day substitute teacher, was gainfully employed on a substantially full-time basis during the year in issue within the scope of section 214 of the Internal Revenue Code of 1954 so that the petitioners are entitled to deduct child care expenses for such year.

All of the facts have been stipulated and are so found.

The petitioners were legal residents of Vancouver, Washington, at the time of the filing of the petition in this case. Their joint income tax return for 1972 was filed with the Internal Revenue Service at Ogden, Utah.

The case was tried and submitted to the Court on November 17, 1975, and on February 20, 1976, petitioners filed an instrument with the Court which is dated February 13, 1976, by which they "concede the above case to the COMMISSIONER OF INTERNAL REVENUE, the respondent; [request that we] discontinue the proceedings and enter*339 a decision in favor of the respondent."

In compliance with such request,

Decision will be entered for the respondent.

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