TIETJENS, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax for the fiscal years ended April 30, 1966 and 1967, in the amounts of $5,187.14 and $12,338.85, respectively. Due to concessions by petitioners only two issues remain for our decision. The first is whether the cost of acquiring certain upland cotton acreage allotments in each of the years in question is an ordinary and necessary business expense under section 162, I...
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