FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for 1964 and 1965 in the amounts of $15,561.34 and $2,049.04, respectively. Certain concessions have been made by both parties, and the only issue remaining for decision is whether the expenditures incurred by Howard Straughn for the subsoiling and leveling of land which he acquired in 1964 are deductible as soil or water conservation expenditures under section 175.
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