CASIDA v. COMMISSIONER

Docket No. 3690-77.

38 T.C.M. 1054 (1979)

T.C. Memo. 1979-267

Donald J. Casida and Gloria M. Fantozzi, formerly known as Gloria M. Casida v. Commissioner.

United States Tax Court.

Filed July 17, 1979.


Attorney(s) appearing for the Case

David L. Shaw, 777 High St., Eugene, Ore., for the petitioners. Jan R. Pierce, for the respondent.


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).1

Findings of Fact

Some of the facts have...

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