Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1971 in the amount of $1,704. Concessions having been made, the only issue remaining for our decision is whether an agreement, which petitioners entered into with respect to their railroad tank car, is a lease, in which case they are not entitled to an investment...
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