OPINION.
We hold against petitioners on this issue. They have failed to prove that the cows were held for breeding or dairy purposes and the length of time held. We find no basis for finding that petitioners were entitled to capital gains treatment under section 117 (j) for the cows sold in 1945.
Reviewed by the Court.
Decision will he entered for the respondent.
Van Fossan, Turner, Harron, and Raum, concur in the result.