RAYMOND B. v. COMMISSIONER

Docket No. 13909-98.

78 T.C.M. 728 (1999)

T.C. Memo. 1999-362

Raymond B. and Joan M. Marvin v. Commissioner.

United States Tax Court.

Filed October 29, 1999.


Attorney(s) appearing for the Case

Raymond B. Marvin, pro se. Timothy F. Salel, for the respondent.


MEMORANDUM OPINION

GOLDBERG, Special Trial Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,765 for the taxable year 1996. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.

The issues for decision are: (1) Whether petitioners' jade activity was an activity engaged in for profit within the meaning of section 183, and (2) if so, whether petitioners...

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