Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By notice of deficiency dated February 23, 1987, respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1982 in the amount of $14,747.
After concessions, the remaining issue for decision is whether petitioner Jean D. Pirnia's show horse activity was engaged in for profit during taxable year 1982 within the meaning of section 183(a).
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