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HARVEY v. COMMISSIONER

Docket No. 4899-85.

54 T.C.M. 1508 (1988)

T.C. Memo. 1988-13

Richard Wayne Harvey and Karen S. Harvey v. Commissioner.

United States Tax Court.

Filed January 11, 1988.

Attorney(s) appearing for the Case

George Fewson, 3100 Arapahoe Ave., Boulder, Colo., for the petitioners. James B. Martin, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioners' 1981 and 1982 Federal income taxes in the amounts of $15,506 and $24,148, respectively, and an addition to tax for 1981 pursuant to section 6651(a)(1)1 in the amount of $298.

The issues for decision are: (1) whether petitioners' horse breeding operation was an "activity not engaged in for profit" within the meaning...

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