Harold W. and Julia A. Kahla - Page 21

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          Conclusion                                                                  
               Giving due consideration to the record as a whole, we conclude         
          that during the years in issue petitioners did not enter into or            
          carry on their cattle-raising and deer operations with an intent to         
          make a profit.  Accordingly, we sustain respondent’s disallowance           
          of petitioners’ Schedule F losses.                                          
               In reaching our conclusions herein, we have considered all             
          arguments presented and, to the extent not discussed above, find            
          them to be without merit.                                                   
               To reflect the foregoing,                                              


                                                       Decision will be               
                                                   entered for respondent.            

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