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DICKSON v. COMMISSIONER

Docket No. 21346-81.

47 T.C.M. 509 (1983)

T.C. Memo. 1983-723

Robert W. Dickson and Jeanne K. Dickson v. Commissioner.

United States Tax Court.

Filed December 5, 1983.

Attorney(s) appearing for the Case

Lawrence J. Hayes, 332 Hamm Bldg., St. Paul, Minn., for the petitioners. Dale L. Newland, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency of $7,398.61 in petitioners' 1979 Federal income tax. The issues for decision are (1) whether petitioners' sailboat activities constitute an activity not engaged in for profit within the meaning of section 183(a),1 (2) whether petitioners miscalculated the salvage value of their sailboat for purposes of the allowance for depreciation under...

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