Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners' income taxes for the calendar year 1961 as follows:
Robert L. and Dorothy G. Maple..... $25,004.26 William M. and Eleanor A. Smith.... 5,015.66
The only issue for determination is whether amounts incurred or expended in connection with the development of orange trees are deductible...
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