Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Year Deficiency 1971 ............. $5,284.34 1972 ............. 2,406.32 1974 ............. 1,053.21 1975 ............. 722.00
The issues for decision are:
1. Whether petitioner Thomas C. Regan's cost basis in a herd of polled Hereford cattle exceeds $6...
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