Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in petitioners' income taxes of $21,130.60 for 1967, $16,895.09 for 1968, $8,767.56 for 1969, and $3,710.57 for 1970. Respondent has conceded that there is no deficiency for 1970. The sole issue is whether petitioners intended to make a profit in operating their cattle ranch. If they did not so intend, then they may not deduct under section 165
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