Memorandum Findings of Fact and Opinion
GALLOWAY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986, and Rule 180 et seq.
By a notice of deficiency, respondent determined a deficiency in petitioners' 1983 Federal income tax liability in the amount of $1,174. The sole issue to be decided is whether petitioners' automobile racing was an activity...
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