T.C. Memo. 1996-67
UNITED STATES TAX COURT
ANTHONY RANCIATO AND LUCILLE RANCIATO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 27159-91. Filed February 20, 1996.
William M. Bloss and Jonathan S. Katz, for petitioners.
John Aletta, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
LARO, Judge: The case is before the Court on remand from
the Court of Appeals for the Second Circuit. The Court of
Appeals questioned our analysis in Ranciato v. Commissioner, T.C.
Memo. 1993-536 (Ranciato I), in which we held that petitioner's
pet store was not an activity entered into for profit during the
* This opinion supplements Ranciato v. Commissioner, T.C.
Memo. 1993-536.
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