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Respondent determined deficiencies of $10,929 and $9,778 in
petitioner’s 1996 and 1997 Federal income taxes, respectively.
This Court must decide (1) whether petitioner engaged in a bed
and breakfast activity for profit within the meaning of section
183 and (2) whether petitioner is entitled to head of household
filing status.
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Killbuck, New York, at the time
he filed his petition.
In 1977, petitioner built a house at 6161 Sullivan Hollow,
Killbuck, New York, 14748 (Sullivan Hollow residence). The
Sullivan Hollow residence has six bedrooms, three full baths, a
living room, kitchen, dining room, deck, hot tub, and two
satellite television systems. Petitioner and his then-wife
jointly held title to the Sullivan Hollow residence and lived
there with their four children. Petitioner and his then-wife
divorced in 1992. In 1993, petitioner purchased his former
wife’s interest in the Sullivan Hollow residence.
During the taxable years in issue, petitioner worked full-
time as an elementary school principal. Petitioner’s job as a
principal required him to work for 11 months annually.
In 1994, petitioner started what he termed The Camelot Inn
Bed & Breakfast (Camelot Inn) at the Sullivan Hollow residence.
During 1996 and 1997, petitioner and his then-fianc�, Mary Ann
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