T.C. Memo. 1998-367
UNITED STATES TAX COURT
JAMES L. SULLIVAN AND DOROTHY B. SULLIVAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3332-96. Filed October 8, 1998.
Bruce Locke, for petitioners.
Roberta L. Shumway, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge: Respondent determined a deficiency of
$21,561.45 in petitioners' Federal income tax for taxable year
1992. The issue for decision is whether petitioners' horse
breeding and showing activities constitute an "activity not
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