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OSTEEN v. C.I.R.

No. 94-2371.

62 F.3d 356 (1995)

Harry E. OSTEEN and Gail M. Osteen, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

August 25, 1995.

Attorney(s) appearing for the Case

David B. Ferebee, Jacksonville, FL, for appellants.

Gary R. Allen, Anthony T. Sheehan, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee.

Before BLACK and BARKETT, Circuit Judges, and RONEY, Senior Circuit Judge.

RONEY, Senior Circuit Judge:

Harry and Gail Osteen (taxpayers) appeal the United States Tax Court's decision disallowing certain tax deductions attributable to their farming and horse breeding operation on the grounds that this activity was not engaged in for profit and assessing tax deficiencies and penalties for a substantial tax understatement.

We hold that the Tax Court's factual findings that the Osteens lacked...

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