T.C. Memo. 1999-326
UNITED STATES TAX COURT
ROBERT BRYAN HUDNALL AND VICTORIA A. HUDNALL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8338-97. Filed September 29, 1999.
Robert Bryan Hudnall and Victoria A. Hudnall, pro sese.
Helen F. Rogers, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax of $3,664 for the
taxable year 1993. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect for the
year in issue, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
The issues for decision are: (1) Whether petitioners'
horse-related activities were engaged in for profit; (2) whether
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