MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $8,532.67 for 1993 and $14,038 for 1994. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issue for decision is whether petitioners are entitled to deduct losses attributable to their yacht chartering activity...
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