United States Tax Court.
Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined the following deficiencies in the Federal income tax of the petitioner:
Taxable Year Deficiency 1974 ............... $57,660 1975 ............... 27,106
Due to concessions, the only issue is whether capital was a material income-producing factor in petitioner's mail order business during the taxable years in question....
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