Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge.
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' 1985, 1986, and 1987 Federal income taxes of $860, $1,547, and $1,979, respectively. After concessions by both parties, the issue for our decision is whether Deborah Aretakis engaged in horse breeding...
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