Memorandum Opinion
WHITAKER, Judge:
Respondent determined deficiencies for the years 1985 and 1986 in the amounts of $5,612.72 and $5,278.85, respectively. The deficiencies result from respondent's disallowance of expenses for the 1985 and 1986 taxable years in the amounts of $28,063.58 and $26,394.29, respectively. Respondent determined that these expenses representing reforestation costs are not deductible and must be capitalized. For convenience, our...
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