Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies in the 1976 and 1977 Federal income taxes of petitioners John and Linda Arrington of $4,250.26 and $6,211.00, respectively. After concessions, the only issue for our decision is whether the expenses of petitioners' stock farm at Beggs, Oklahoma [,] are deductible under either sections 162 or 212,
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