Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1961 and 1962 in the amounts of $1,514 and $2,323, respectively. The issue for decision is whether the sheep in petitioner's breeding herd had a basis in excess of zero at the time petitioner disposed of them.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
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