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satisfied the Court that profit, rather than hobby, was the
motive for his expenditures.3 We sustain respondent’s
determination under section 6662(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
3 Respondent has established his burden of production under
sec. 7491(c).
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Last modified: May 25, 2011