Memorandum Findings of Fact and Opinion
CHABOT, Judge:
Respondent determined deficiencies in Federal individual income tax against petitioners for 1979 and 1980 in the amounts of $4,170 and $5,968, respectively. The issue for decision is whether petitioners' horse-racing and horse-breeding activities constitute a trade or business, or an "activity * * * not engaged in for profit", within the meaning of section 183(a).
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