MEMORANDUM FINDINGS OF FACT AND OPINION
CLAPP, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Year Deficiency 1990 ..................... $3,100 1991 ..................... 9,329
After concessions by the parties, the issues for decision are:
(1) Whether payments made to North Carolina and Virginia resulting from deficiencies in fertilizer...
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