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 otherwise
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