Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $9,063.73 in the income tax of the petitioner for 1947. The principal issue in the case was whether the owning, training, racing and breeding of harness race horses was a business, the losses of which were deductible under section 23 (e) (1), or was a hobby. The Commissioner has conceded that that operation was a business and the...
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