Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioners' income tax for the taxable year 1968 in the amount of $5,145. The parties have conceded some of the issues. The issues remaining to be decided are as follows:
1. Was Petitioner James M. Ferguson, Sr. a "dealer" in commodities thereby entitling him to use inventories to determine his profits or losses or was he, instead, an "investor" or...
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