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Finally, petitioners argue that we should lean in favor of
allowing them to deduct their losses in order to encourage risk-
taking and innovation to help the American economy thrive. The
short answer is that section 183 denies the deduction of losses
from activities not engaged in for profit.
We therefore uphold respondent’s determination that
petitioners’ horse-breeding activity was not “engaged in for
profit” within the meaning of section 183.
To reflect the foregoing and the stipulations of the parties
on other issues,
Decision will be entered
under Rule 155.
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