COPELAND v. COMMISSIONER

Docket No. 1642-78.

41 T.C.M. 253 (1980)

T.C. Memo. 1980-476

Herbert B. Copeland and Elaine Copeland v. Commissioner.

United States Tax Court.

Filed October 23, 1980.


Attorney(s) appearing for the Case

Theodore W. Hirsh, 10 Light St., Baltimore, Md., James N. Schuth and Harold Altscher, for the petitioners. R. Dale Eggleston, for the respondent.


Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner, in his statutory notice, determined a deficiency of $1,537 in petitioners' Federal income tax for their taxable year 1975. The issue is whether petitioners' operation of their beach cottage (hereinafter the cottage) for that year was an "activity * * * not engaged in for profit" within the meaning of section 183(a), Internal Revenue Code of 1954.1

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