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affd. 400 F.2d 584 (9th Cir. 1968); Hinz & Landt, Inc. v.
Commissioner, 8 B.T.A. 375, 379 (1927); see also Perry v.
Commissioner, 49 T.C. 508 (1968); cf. Blue Flame Gas Co. v.
Commissioner, 54 T.C. 584, 599-600 (1970); Estate of Faris v.
Commissioner, T.C. Memo. 1955-268.
Thus, we conclude that the farming losses resulting from
petitioner's cattle-ranching activities are those of Spirit Horse
Ranch, a New Mexico corporation, and not that of petitioner.
Consequently, petitioner is not entitled to deduct those losses on
her Federal income tax returns for the years in issue.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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