Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies in income tax for the calendar years 1944, 1945 and 1946 of $11,819.80, $13,126.07 and $7,153.81, respectively. The sole issue is whether certain cattle sold by petitioners in the taxable years were held for breeding purposes or held primarily for sale to customers in the course of the taxpayers' business. The case was submitted upon a partial stipulation of facts...
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