CANALE v. COMMISSIONER

Docket No. 8708-88.

58 T.C.M. 694 (1989)

T.C. Memo. 1989-619

Wayne Canale v. Commissioner.

United States Tax Court.

Filed November 15, 1989.


Attorney(s) appearing for the Case

Jay Fetman, 4711 W. Golf Rd., Skokie, Ill., for the petitioner. Jonathan P. Decator, for the respondent.


Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a $3,536 deficiency in petitioner's Federal income tax for the taxable year 1985. After respondent's concessions, the only issue is whether petitioner engaged in his motorcycle racing activities for profit within the meaning of section 183.1

Findings of Fact

Some of the facts are stipulated and are so found. The stipulation of facts...

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