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In summation, petitioners were not engaged in a trade or
business activity within the intent and meaning of section
162(a). Respondent is sustained on this issue. However,
petitioners are entitled to a depreciation deduction and
additional deductions of $3,592.66 as Schedule E deductions,
under section 212(1) and (2), relating to their Florida
condominium.
Decision will be entered
under Rule 155.
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