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KEELTY v. COMMISSIONER

Docket No. 3405-82.

47 T.C.M. 1455 (1984)

T.C. Memo. 1984-173

Joseph S. Keelty v. Commissioner.

United States Tax Court.

Filed April 4, 1984.

Attorney(s) appearing for the Case

Herbert S. Garten, 36 South Charles Street, Baltimore, Md., and Sheldon G. Dagurt, for the petitioner. Clare J. Brooks and Mary Corrigan Gorman, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

  Year               Deficiency

  1976 ...........    $17,716
  1977 ...........     24,742
  1978 ...........     26,640

The sole issue for decision is whether petitioner's farming activity constituted a trade or business or an "activity not engaged in for profit" within the meaning...

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