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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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