Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $1,741.00 in petitioners' 1979 Federal income tax. The only issue is whether petitioners' auto racing was an activity not engaged in for profit under section 183.
Findings of Fact
Some of the facts have been stipulated and are so found.
Petitioners, Homer Arthur Woods (hereinafter petitioner) and Barbara Ann Woods...
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