T.C. Memo. 1999-362
UNITED STATES TAX COURT
RAYMOND B. AND JOAN M. MARVIN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13909-98. Filed October 29, 1999.
Raymond B. Marvin, pro se.
Timothy F. Salel, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: Respondent determined a
deficiency in petitioners' Federal income tax in the amount of
$2,765 for the taxable year 1996. Unless otherwise indicated,
section references are to the Internal Revenue Code in effect for
the year in issue.
The issues for decision are: (1) Whether petitioners' jade
activity was an activity engaged in for profit within the meaning
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