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obtain a sailboat incidental to the receipt of petitioners’
cleaning, maintenance, and repair services. Therefore, we
conclude that petitioners did not contribute extraordinary
personal services to their sailboat charter business during the
years in issue.
Accordingly, we sustain respondent’s determination
disallowing petitioners’ business losses.
We have considered all of petitioners’ arguments, and, to
the extent that we have not specifically addressed them, we
conclude they are without merit.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011