MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
For 1990, respondent determined that petitioners have a deficiency in income tax of $42,911 and are liable for a penalty under section 6662(a) of $8,582.
The issues for decision are:
1. Whether petitioners' police dog training business was a sole proprietorship or a C corporation in 1990. If it was a sole proprietorship, petitioners may deduct its net loss of $159,426 on their individual...
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