T.C. Memo. 2005-188
UNITED STATES TAX COURT
LEONARD RABINOWITZ AND M. CAROLE RABINOWITZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5595-02. Filed July 27, 2005.
William M. Weintraub and Brian Wright, for petitioners.
Jack H. Klinghoffer, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined deficiencies of
$257,242 for 1992, $774,708 for 1993, $1,409,667 for 1994 and
$150,837 for 1997 in petitioners’ Federal income taxes.1 The
parties have settled all issues except whether petitioners
operated their jet charter activity for profit from 1993 through
1All section references are to the Internal Revenue Code for
the relevant years unless otherwise indicated, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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