Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $102,200 and $98,128 for 1982 and 1983, respectively. After concessions, the issue presented is whether petitioner engaged in a thoroughbred breeding and racing activity with an actual and honest profit objective.
Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits...
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