Memorandum Opinion
MULRONEY, Judge:
The Commissioner determined a deficiency of $6,720.31 in income tax for the year 1951. The issues are (1) whether certain immature ewes held by the petitioners on December 31, 1951, are properly includible in inventory, or, as the respondent contends, are to be capitalized as part of the breeding herd, and (2) whether the basis for depreciation purposes in 1951 of certain mature breeding ewes, acquired in prior years,...
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