MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $7,952 for 1994 and $4,788 for 1995.
The issues for decision are:
1. Whether petitioners operated their tree farm activity for profit in 1994 and 1995. We hold that they did not.
2. Whether the limitation on the time to assess tax for 1994 or 1995 expired before respondent issued the notice of deficiency...
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