Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined deficiencies in the Federal income taxes of petitioners for the designated years in the following amounts:
Year Deficiency 1968 .................. $5,891.63 1969 .................. 5,403.00 19701 ............ 4,460.92
The issues presented for decision are (1) whether the horse activities conducted...
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