Otis W. Jordan and Alma F. Jordan - Page 12




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          involving Jordan’s Tan.  That being so, the breeding fees                   
          deducted on the Schedule F must, instead, be capitalized.  See              
          Duggar v. Commissioner, supra.                                              
               Petitioners are entitled to the deductions claimed on the              
          Schedule F that have not been specifically addressed in the                 
          discussion portion of this opinion.                                         
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered under Rule 155.                  
































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