Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Tax Year Ended Deficiency December 31, 1980 ........... $8,836.10 December 31, 1981 ........... 8,984.55
After concessions, the sole issue remaining for decision is whether petitioners' farming activity
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