OPINION.
RAUM, Judge:
Petitioners are husband and wife residing in River Forest, Illinois. On or before March 15, 1952, they filed a joint income tax return for the calendar year 1951 with the collector of internal revenue for the first collection district of Illinois, at Chicago. The facts have been stipulated and are not in dispute.
In 1951 Patricia M. Fleming, petitioner, was a partner in Milky Way Hereford Ranch, entitled to share in income...
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