Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies of $2,252.34 and $3,539.71 in petitioners' Federal income tax for taxable years 1972 and 1973, respectively. After concessions, the sole issue is whether petitioner Donald J. Casida's drag racing was an "activity * * * not engaged in for profit" within the meaning of section 183(a).
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