Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency in petitioners' 1961 joint Federal income tax in the amount of $2,861.51. Petitioners' having abandoned at trial their challenge of respondent's adjustments to their claimed depreciation deduction, the only issue remaining for our decision is whether petitioners' daughter was the owner during 1961 of certain equipment known as "power tongs," or whether petitioner, Millard...
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