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DELL v. COMMISSIONER

Docket Nos. 11187-81, 29871-82.

48 T.C.M. 1430 (1984)

T.C. Memo. 1984-556

Samuel R. Dell and Eleanor Dell v. Commissioner.

United States Tax Court.

Filed October 17, 1984.

Attorney(s) appearing for the Case

Gerald W. Dibble and David H. Kernan, One Exchange St., Rochester, N.Y., for the petitioners. Michael Sheeley, for the respondent.

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes as follows:

  Year            Deficiency

  1977 .......... $29,044.581
  1978 ..........  15,145.00
  1979 ..........   8,317.00
  1980 ..........   6,790.00

The only question before the Court is whether petitioners' cattle breeding operation was an activity "engaged in...

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