ESTATE OF LANIER v. COMMISSIONER

Docket No. 10080-77.

40 T.C.M. 863 (1980)

T.C. Memo. 1980-295

Estate of Estelle H. Lanier, deceased, Nicholas R. Doman, Executor v. Commissioner.

United States Tax Court.

Filed August 5, 1980.


Attorney(s) appearing for the Case

Peter D. Oram, 420 Lexington Ave., New York, New York, for the petitioner. Tracy L. Rich and Ellis L. Reemer, for the respondent.


Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined income tax deficiencies of $2,821.30 for 1971 and $60 for 1972. The issue for decision is whether respondent properly disallowed Estelle Lanier's net losses from the Lanier-Ballich joint venture, a dog kennel operation, because the activity was not engaged in for profit during 1971 and 1972.

Findings of Fact

Some of the facts have been stipulated and are found accordingly...

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