Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined income tax deficiencies against the petitioners for the years 1963 and 1964 in the respective amounts of $1,540.37 and $1,076.63.
The adjustments made by respondent result from the disallowance of claimed deductions for losses sustained by petitioners in connection with a horse farm. The only issue for decision is whether the petitioners are entitled to deduct the losses...
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