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BISHOP v. COMMISSIONER

Docket No. 5031-70.

31 T.C.M. 829 (1972)

T.C. Memo. 1972-167

James S. Bishop and Karen M. Bishop v. Commissioner.

United States Tax Court.

Filed August 7, 1972.

Attorney(s) appearing for the Case

Marvin S. Zelman, 15th Floor, Central Nat'l Bk. Bldg., Cleveland, Ohio, for the petitioners. Buckley D. Sowards, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income tax as follows:

  Taxable Year        Amount

     1967 .........  $2,541.70
     1968 .........   3,197.00

The issue presented for adjudication is whether the expenses incurred by the petitioners in the racing and breeding of horses are deductible under the provisions of section 162(a),

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