Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1962 and 1963 in the amounts of $1,100.02 and $751.86, respectively.
The only issue is whether petitioner may deduct the sums of $5,500 in 1962 and $3,500 in 1963 paid to petitioner's brother, allegedly for the care and feeding of petitioner's cattle, as losses incured in the business of raising cattle in those years...
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