ARUNDELL, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1958 in the amount of $2,827.53. The remaining issue left for decision arose out of respondent's holding that the sum of $8,202.16 expended for construction of an earthen dam and the leveling of land on petitioners' farm constituted soil and water conservation expenses and is deductible only under the provisions and limitations of section 175 of the Internal Revenue...
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