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REMUZZI v. COMMISSIONER

Docket No. 32962-85.

54 T.C.M. 1479 (1988)

T.C. Memo. 1988-8

Robert and Rachael Remuzzi v. Commissioner.

United States Tax Court.

Filed January 6, 1988.

Attorney(s) appearing for the Case

F. Brook Voght, 655 Fifteenth St., Washington, D.C., and Martin Scully, Jr., for the petitioners. Alan C. Levine, for the respondent.

Memorandum Findings of Fact and Opinion

KORNER, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year                                Deficiency

1980 ............................   $10,722.93
1981 ............................    15,857.03

After concessions, the issues for decision are: (1) Whether petitioners' farm was an "activity not engaged in for profit" within the meaning...

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