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HRDLICKA v. COMMISSIONER

Docket No. 7320-84.

50 T.C.M. 675 (1985)

T.C. Memo. 1985-403

Larry J. Hrdlicka and Frances Hrdlicka v. Commissioner.

United States Tax Court.

Filed August 7, 1985.

Attorney(s) appearing for the Case

Ted M. Riseling and Thomas J. St. Ville, 2200 Fourth National Bldg., Tulsa, Okla., for the petitioners. Bruce K. Meneely, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' income tax in the amounts of $8,079.44, $9,079, and $7,809 for the taxable years 1978, 1979, and 1980, respectively. After a concession by petitioners, the only issue for decision is whether petitioners operated their cattle ranch as an "activity *** not engaged in for profit" within the meaning of section 183(a).1<...

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