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SOUSA v. COMMISSIONER

Docket No. 22941-86.

58 T.C.M. 515 (1989)

T.C. Memo. 1989-581

Norman R. Sousa v. Commissioner.

United States Tax Court.

Filed October 26, 1989.

Attorney(s) appearing for the Case

Daniel E. Goldrick, for the petitioner. Mary P. Hamilton, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable years 1981 and 1982 in the respective amounts of.$26,423 and $8,303.

The issue for decision is whether petitioner's boat chartering activity was engaged in for profit within the meaning of section 1831 and, if so, whether petitioner is entitled to deduct depreciation claimed in the...

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