T.C. Memo. 1996-285 UNITED STATES TAX COURT JAMES C. VALLETTE AND ARLEEN R. VALLETTE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3380-94. Filed June 20, 1996. James Alvin Watson, for petitioners. Emile L. Hebert III, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: James C. Vallette and Arleen R. Vallette petitioned the Court to redetermine respondent’s determination of deficiencies in their 1989 and 1990 Federal income taxes. Respondent determined an $18,990 deficiency for 1989 and a $14,840 deficiency for 1990. Following concessions by the parties, we must decide whether petitioners operated a cattle breeding activity with the requisite profit objective within the meaning of section 183. We hold they did not. Unless otherwisePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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