Julius Lee Harrington and Mary Lou Ziter - Page 21




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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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