HOYT, Judge:
Respondent determined deficiencies of $11,018.48 and $22,312.75 in joint income taxes of petitioners for 1960 and 1961, respectively. Certain issues have been settled between the parties. A preliminary issue is whether the statutory notice of deficiency constitutes a determination which places the burden of proof to show error in the determination upon the petitioners. The principal issue remaining is whether petitioners are entitled to depreciation...
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