Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1956 and 1957 in the respective amounts of $26,278.97 and $14,711.12.
The issues for decision are:
(1) Whether Rowe B. Metcalf, who will hereafter be referred to as petitioner, was engaged during the years 1956 and 1957 in the business of farming so that losses incurred by him in the operation of a farm during...
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