Memorandum Findings of Fact and Opinion
TRAIN, Judge:
The respondent determined a deficiency in petitioners' income tax for the year 1953 in the amount of $7,929.86.
The sole issue for decision is whether petitioners were engaged in a trade or business of breeding, training and showing horses during 1953 with the result that they may claim a deductible loss therefrom in the amount of $12,548.98.
Findings of Fact
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