BUMGARDNER v. COMMISSIONER

Docket Nos. 40912, 40913.

13 T.C.M. 128 (1954)

Amos S. Bumgardner and Ann H. Bumgardner v. Commissioner. Amos S. Bumgardner v. Commissioner.

United States Tax Court.

Entered February 10, 1954.


Attorney(s) appearing for the Case

Carlisle W. Higgins, Esq., 410 Reynolds Building, Winston-Salem, N. C., and F. T. Miller, Jr., Esq., for the petitioners. Stanley Schoenbaum, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

This proceeding involves deficiencies in income taxes for the calendar years 1947, 1948 and 1949 in the amounts of $2,050.35, $3,675.98 and $1,552.08, respectively.

These deficiencies result from the disallowance of certain deductions in these years attributable to expenses and losses from the operation of a dog kennel. The single question to be determined is whether the kennel was operated as a business during the...

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