KAHLE v. COMMISSIONER

Docket No. 5633-89.

61 T.C.M. 2560 (1991)

T.C. Memo. 1991-203

Paul J. Kahle and Vanessa A. Kahle v. Commissioner.

United States Tax Court.

Filed May 13, 1991.


Attorney(s) appearing for the Case

Jeannette A. Cyphers, for the petitioners.

Dorinda J. Myers-Ohnstad and Terri A. Merriam, for the respondent.


Memorandum Findings of Fact and Opinion

KORNER, Judge.

By a timely sent notice of deficiency, respondent determined deficiencies in petitioners' 1985 and 1986 Federal income tax of $4,897 and $6,228, respectively. The issues for decision are: (1) Whether petitioners' yacht-chartering activity was an activity not engaged in for profit; (2) whether petitioners placed their yacht in service in 1985; and (3) whether petitioners are entitled to an investment...

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