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TRAFFICANTE v. COMMISSIONER

Docket No. 14676-88.

60 T.C.M. 110 (1990)

T.C. Memo. 1990-353

Santo J. Trafficante and Geraldine L. Trafficante v. Commissioner.

United States Tax Court.

Filed July 11, 1990.

Attorney(s) appearing for the Case

Charles F. Clark and Matthew J. Foster, 215 Madison St., Tampa, Fla., for the petitioners. Francis C. Mucciolo and William R. McCants, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge.

Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1983 and 1984 in the respective amounts of $35,965 and $26,083.

The only issue for decision is whether petitioners' horse operation was engaged in "for profit" within the meaning of section 183.1

Finding of Fact

Some of the facts have been stipulated and are...

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