Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency of $12,087 in petitioner's Federal income taxes for the taxable year ended June 30, 1973 and a deficiency of $25,990 for the taxable year ended June 30, 1974. Some of the issues have been conceded, leaving the following issues for our adjudication:
(1) Whether certain structures known as merchandising huts or merchandising units are tangible personal property...
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