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FOSTER v. COMMISSIONER

Docket No. 165-71.

32 T.C.M. 48 (1973)

T.C. Memo. 1973-14

Rex B. Foster, Jr., and Barbara Foster v. Commissioner.

United States Tax Court.

Filed January 23, 1973.

Attorney(s) appearing for the Case

Marion Hirschburg, 801 Ridgewood, Ames, Iowa, for the petitioners. Robert J. Murray, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined the following deficiencies in petitioners' income taxes:

  Year                   Deficiency

  1964 ...............   $ 7,181.35
  1965 ...............    20,174.27
  1966 ...............     9,952.83
  1967 ...............    21,626.12

We must decide whether petitioners were engaged in the business of breeding and raising Tennessee Walking Horses (hereafter...

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