The Commissioner determined deficiencies in petitioners' income tax in the amounts of $11,530.44, $23,501, and $16,040 for the calendar years 1967, 1968, and 1969, respectively. Petitioner acquired two orange groves, paying $4,500 per acre in respect of each of them over a period of approximately 4 years each. The principal question is whether portions of such amounts may be allocated to services for "management and care" of the groves performed by the seller and thus treated...
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