Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1960, 1961, 1962 and 1963 in the amounts of $11,977.15, $14,310.23, $35,119.49 and $33,890.81, respectively.
During the years in question petitioner Susan Briggs Fisher carried on horse racing and horse breeding activities and the issue here is whether such activities constituted the carrying on of a trade or business...
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