Memorandum Findings of Fact and Opinion
RUWE, Judge.
Respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $2,139 and $3,394 for the taxable years 1982 and 1983, respectively. Respondent also determined that petitioner is liable for an addition to tax, in the amount of $535, for failure to timely file his 1982 Federal income tax return. The issues for decision are: (1) whether petitioner's off-road racing activity was...
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