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PLUNKETT v. COMMISSIONER

Docket No. 13819-81.

47 T.C.M. 1439 (1984)

T.C. Memo. 1984-170

H. Connely Plunkett and Iris Plunkett v. Commissioner.

United States Tax Court.

Filed April 3, 1984.

Attorney(s) appearing for the Case

Lauch M. Magruder, Jr., 1800 Deposit Guaranty Plaza, Jackson, Miss., for the petitioners. Jillena Warner and Katherine S. Weed, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax for taxable years 1977 and 1978 in the amounts of $7,827.83 and $1,409, respectively. After concessions by the parties, the only issue for decision is whether petitioners' mud-racing and truck-pulling activities constitute an "activity * * * not engaged in for profit" within the meaning of section 183(a).1

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