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WANN v. COMMISSIONER

Docket No. 2301-66.

27 T.C.M. 1301 (1968)

T.C. Memo. 1968-246

Billy V. and Betty L. Wann v. Commissioner.

United States Tax Court.

Filed October 28, 1968.

Attorney(s) appearing for the Case

Betty L. Wann and Billy V. Wann, pro se, Box 17, Hopland, Calif. Sheldon M. Sisson, for the respondent.

Memorandum Findings of Fact and Opinion

HOYT, Judge:

Respondent determined the following income tax deficiencies against petitioners:

  Taxable
   Year                  Deficiency

   1962 ...............  $  712.60
   1963 ...............   1,667.48
   1964 ...............   1,349.87

The primary issue for decision is whether or not the petitioners' farming activities constituted a trade or business or, alternatively, a venture...

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