TRAIN, Judge:
The respondent determined deficiencies in petitioner's income tax for the years 1952 and 1954 in the amounts of $206,024.50 and $303,970.93, respectively.
The issues for decision are:
(1) Whether petitioner's deductions arising from the operation of a ranch in excess of petitioner's gross income from the ranch plus $50,000 per year plus specially treated deductions were properly disallowed under section 270 of the Internal Revenue...
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