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MASSINGILL v. COMMISSIONER

Docket No. 19193-94.

71 T.C.M. 2651 (1996)

T.C. Memo. 1996-162

Mark Massingill and Indra Massingill v. Commissioner.

United States Tax Court.

Filed March 28, 1996.

Attorney(s) appearing for the Case

Mark and Indra Massingill, pro sese. David W. Sorenson, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a $11,006 deficiency in petitioners' 1990 Federal income tax. Respondent also determined an addition to tax under section 6651(a)(1)1 of $1,917 and an accuracy-related penalty under section 6662(a) of $1,390. After concessions, the issues remaining for our consideration are: (1) Whether, in 1990, petitioners were engaged in an activity for profit pursuant...

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