The respondent determined deficiencies in petitioners' income tax for the taxable year 1949 in the sum of $3,480.96 by disallowing a deduction of $12,000 claimed by them as rental expense paid for the use of 160 acres of farm land. The only question presented is whether the payment by petitioners made under the "lease" was in fact rent or whether it constituted a partial payment on the purchase price of the property by means of which petitioners acquired an equity therein...
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