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Because petitioner's dog breeding activity was not an
activity engaged in for profit, the activity cannot be considered
a trade or business for purposes of section 162(a). Therefore,
she is only entitled to deduct the expenses incurred in that
activity in accordance with section 183. It follows, and we
hold, that respondent's determination in this regard is
sustained.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011