Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a deficiency of $4,807 in petitioner's Federal income tax for taxable year 1983. The sole issue to be decided is whether petitioner's activities as a treasure hunter and marine archaeological explorer were engaged in for profit.
Findings of Fact
Some of the facts have been stipulated and are so found. The stipulated facts and attached exhibits are incorporated herein...
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