Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income taxes for 1984, 1985, and 1986 in the amounts of $17,829.00, $13,324.57, and $20,736.00, respectively. After concessions relating to the 1985 real estate activity of Nance Lewis, the sole issue for decision is whether petitioners' sailboat chartering activity was "not engaged in for profit" within the meaning of section 183.
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