Melissa S. Spranger - Page 13




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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