Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined the following deficiencies in petitioners' Federal income tax:
Taxable Year Deficiency 1976 ............ $13,460.60 1977 ............ 30,302.00
Due to concessions, the only issue before us is whether capital was a material income-producing factor in petitioners' egg-producing business during the taxable years in issue....
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