BARRETT, Circuit Judge.
L.O. and Myra Ward (Wards) appeal from a judgment entered in favor of the United States. Wards initiated this action seeking a tax refund. The dispositive facts are not in dispute.
Wards are independent oil and gas producers who have operated as a sole proprietorship since 1964, when L.O. Ward first began oil and gas operations on his own account. At that time, the Wards exercised
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