Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined a deficiency in the income taxes of petitioners for the years 1961, 1962 and 1963 in the amounts of $1,118.04, $1,517.24 and $2,427.21, respectively. The primary issue is whether petitioners are entitled to deduct losses incurred in the operation of a cattle ranch under either section 162 of the Internal Revenue Code of 1954
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