HENLEY, Circuit Judge.
Appellants Juhl and Vera Smith, hereafter referred to jointly as "taxpayer," appeal from a decision of the United States Tax Court entered on July 24, 1975 that taxpayer owed a deficiency of $8,014.31 for 1969 income taxes. This court has jurisdiction pursuant to 26 U.S.C. § 7482.
The facts essentially are undisputed. Taxpayer and his brother each owned an undivided one-half interest in 120 acres of irrigated farm land in Dawson...
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