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THIBAULT v. COMMISSIONER

Docket Nos. 2353-93, 20388-93.

68 T.C.M. 831 (1994)

T.C. Memo. 1994-482

Robert J. Thibault and Patricia Thibault v. Commissioner.

United States Tax Court.

Filed October 4, 1994.

Attorney(s) appearing for the Case

Joseph Falcone, 3000 Town Center, Southfield, Mi., for the petitioners. Lenora R. Roland, for the respondent.

Memorandum Findings of Fact and Opinion

CHIECHI, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1989, 1990, and 1991 in the amounts of $4,363, $5,696, and $4,139, respectively.

The issue remaining for decision is whether petitioner Robert J. Thibault conducted his charter boat fishing activity during the years at issue with the objective of making a profit within the meaning of section 183.1

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