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STEELE v. COMMISSIONER

Docket No. 6299-79.

41 T.C.M. 1092 (1981)

T.C. Memo. 1981-118

James R. Steele and Elizabeth A. Steele v. Commissioner.

United States Tax Court.

Filed March 16, 1981.

Attorney(s) appearing for the Case

James R. Steele, pro se, Baton Rouge, La. Robert J. Burbank, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1974 and 1975 of $2,222.83 and $2,746.76, respectively. The issues presented are whether petitioners' involvement in dog breeding and showing is an "activity not engaged in for profit" within the meaning of section 1831 and, if such activity was engaged in for profit, whether petitioners are entitled to...

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