Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1961, 1962, and 1963 in the amounts of $792.39, $844.38, and $1,620.14, respectively.
The sole issue for determination is whether amounts expended by petitioners in the operation of the Pony Tail Ranch are deductible as expenses incurred in a trade or business within the purview of section 162 of the Internal Revenue...
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