PICKERING v. COMMISSIONER OF INTERNAL REVENUE

No. 79-1711.

652 F.2d 616 (1981)

Norman R. PICKERING and Caroline W. Pickering, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

April 30, 1981.


Attorney(s) appearing for the Case

Alan C. Housholder, Housholder & Housholder, Nashville, Tenn., for petitioners-appellants.

M. Carr Ferguson, Gilbert E. Andrews, Asst. Attys. Gen., Tax Div., U. S. Dept. of Justice, Lester Stein, Acting Chief Counsel, Internal Revenue Service, Gary R. Allen, Libero Marinelli, Jr., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before KEITH and JONES, Circuit Judges, and ENSLEN, District Judge.


ORDER

Norman and Caroline Pickering appeal from the tax court's judgment determining deficiencies in federal income taxes for the years 1972 and 1973 in the total amount of $10,985.75. The sole issue on appeal is whether the tax court's findings of fact in support of its decision that the Pickerings were not engaged in farming activity with the primary objective of making a profit are clearly erroneous.

It is well settled that the Pickerings have...

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