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RABINOWITZ v. COMMISSIONER

Docket No. 5595-02.

90 T.C.M. 113 (2005)

T.C. Memo. 2005-188

Leonard Rabinowitz and M. Carole Rabinowitz v. Commissioner.

United States Tax Court.

July 27, 2005.

Attorney(s) appearing for the Case

William M. Weintraub and Brian Wright, for petitioners.

Jack H. Klinghoffer, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined deficiencies of $257,242 for 1992, $774,708 for 1993, $1,409,667 for 1994 and $150,837 for 1997 in petitioners' Federal income taxes.1 The parties have settled all issues except whether petitioners operated their jet charter activity for profit from 1993 through 1997 (the relevant years).2 We hold that petitioners operated...

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