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KEATING v. C.I.R.

Nos. 07-3660, 08-1266.

544 F.3d 900 (2008)

Nora E. KEATING and Richard L. Shearer, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: October 14, 2008.

Attorney(s) appearing for the Case

Jon J. Jensen, Pearson & Christensen, Grand Forks, ND, for petitioners.

Nathan J. Hochman, Assistant Attorney General, Thomas J. Clark and Teresa T. Milton, U.S. Department of Justice, Washington, DC, for respondent.

Before MURPHY, ARNOLD, and BENTON, Circuit Judges.

MURPHY, Circuit Judge.

Nora E. Keating and Richard L. Shearer filed a petition in United States Tax Court challenging the determination of the Commissioner of Internal Revenue (Commissioner) that because Keating engaged in her horse breeding activity as a hobby rather than for profit, losses from the activity were incorrectly deducted on their 1996 through 2002 tax returns, resulting in deficiencies in their federal income...

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