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HARRISON v. COMMISSIONER

Docket No. 26617-93.

72 T.C.M. 1258 (1996)

T.C. Memo. 1996-509

Frederick G. Harrison, Sr. and Estate of Catherine Harrison, Deceased v. Commissioner.

United States Tax Court.

Filed November 14, 1996.

Attorney(s) appearing for the Case

Dermot F. Kennedy, for the petitioners. James C. Fee, Jr., for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge:

Respondent determined a $62,125 deficiency in petitioners' 1989 Federal income tax and a $12,425 accuracy-related penalty for that year.

The issues for decision are: (1) Whether a gold mining and treasure salvaging activity1 was not engaged in for profit by petitioner2 and thus, losses claimed in connection with this activity were not...

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