Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the years 1977, 1978 and 1979 in the amounts of $2,571, $2,795, and $3,400.16, respectively. After concessions by petitioner, the sole issue remaining for decision is whether petitioner's drag racing activity during the years in question was an activity engaged in for profit under...
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