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BARBOUR v. COMMISSIONER

Docket No. 5204-73.

35 T.C.M. 360 (1976)

T.C. Memo. 1976-85

Thomas E. Barbour and Cora B. Barbour v. Commissioner.

United States Tax Court.

Filed March 18, 1976.

Attorney(s) appearing for the Case

John R. McInnis and Sherman V. Lohn, 199 W. Pine, P.O. Box 1471, Missoula, Mont., for the petitioners. C. Garold Sims, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined deficiencies in petitioners' income taxes of $21,130.60 for 1967, $16,895.09 for 1968, $8,767.56 for 1969, and $3,710.57 for 1970. Respondent has conceded that there is no deficiency for 1970. The sole issue is whether petitioners intended to make a profit in operating their cattle ranch. If they did not so intend, then they may not deduct under section 1651

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