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After concessions,1 the issues remaining for decision are:
(1) Whether petitioners' horse racing and breeding activity
during 1987, 1988, 1989, and 1990 was an activity "not engaged in
for profit" within the meaning of section 183; and (2) whether
petitioners are liable for additions to tax pursuant to section
6651.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and second stipulation of facts are
incorporated herein by this reference. At the time the petition
was filed, petitioners resided in Walnutport, Pennsylvania.
During the years at issue, Ms. Taras was employed as a full-
time secretary in the accounting department at Bethlehem Steel
Corp. (Bethlehem). Ms. Taras worked 40 hours per week at
Bethlehem. On their 1987, 1988, 1989, and 1990 Federal joint
income tax returns, petitioners reported gross income from
Bethlehem in the amounts of $26,690, $27,458, $29,576, and
$31,804, respectively.
1Petitioners concede that the notice of deficiency for 1987
improperly allowed a gambling loss deduction in the amount of
$3,701, thereby erroneously reducing taxable income by $3,701.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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