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BENNETT LAND CO. v. COMMISSIONER

Docket No. 3924-75.

70 T.C. 904 (1978)

BENNETT LAND COMPANY (A WASHINGTON CORPORATION), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 13, 1978.

Attorney(s) appearing for the Case

Wesley A. Nuxoll, for the petitioner.

Thomas M. Tomashek, for the respondent.

IRWIN, Judge:

Respondent determined a deficiency of $1,210 in petitioner's corporate income tax return for the fiscal year ending August 31, 1973.

The only issue presented for our consideration is whether a purchaser of farmland may deduct the portion of the purchase price attributable to the value of summer fallow as a trade or business expense under section 162.1

FINDINGS...

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