Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency of $10,266.14 in petitioners' 1980 income tax. After concessions, including respondent's admission at trial that petitioners are entitled to a loss deduction with regard to their well and water system in the amount of $1,546, the only issue remaining for decision is what amount if any are petitioners entitled to deduct under section 165
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