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THOMASON v. COMMISSIONER

Docket No. 8746-95.

74 T.C.M. 1012 (1997)

T.C. Memo. 1997-480

Harry E. Thomason and Estate of Hattie D. Thomason, Deceased, Mary T. Crist, Personal Representative v. Commissioner.

United States Tax Court.

Filed October 22, 1997.

Attorney(s) appearing for the Case

John R. Foley, for the petitioners. Leslie H. Finlow, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1

Respondent determined a deficiency of $5,331 in petitioners' Federal income tax for 1991.

The issues for decision are: (1) Whether petitioners were engaged in a trade or business activity within the intent and meaning of section 162(a) and, (2) if petitioners were not engaged in...

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