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DOWNS v. COMMISSIONER

Docket No. 5087-77.

37 T.C.M. 1851 (1978)

T.C. Memo. 1978-502

Robert and Eula Downs v. Commissioner.

United States Tax Court.

Filed December 20, 1978.

Attorney(s) appearing for the Case

Gary A. Ward, 5010 University, Lubbock, Tex., and George D. McDonald, for the petitioners. Frank C. Hider, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $8,805.53 in petitioners' Federal income tax for 1973. The issue for decision is whether petitioners are entitled under section 162(a)1 to deduct as an ordinary and necessary expense of their cattle feeding business the sum of $27,500 which they paid for 1 million pounds of grain in 1973.

Findings of Fact<...

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