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GOLANTY v. COMMISSIONER

Docket No. 10325-76.

72 T.C. 411 (1979)

STANLEY A. GOLANTY, LORRIEE M. GOLANTY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 5, 1979.

Attorney(s) appearing for the Case

Jeffrey L. Davidson and William K. Carr, for the petitioners.

Charles O. Cobb, for the respondent.

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $12,180 for 1972 and $9,031 for 1973. The only issue for decision is whether the petitioners' Arabian horse-breeding operation was an "activity * * * not engaged in for profit" within the meaning of section 183(a) of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

Some...

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