Dora Margaret Benson - Page 14




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                                     Conclusion                                       
              For the reasons discussed above, and on the basis of all of             
         the facts and circumstances present in this case, we hold that               
         petitioner was not engaged in any of the activities at issue with            
         the profit objective contemplated by section 183.  See also Rule             
         142(a); INDOPCO, Inc. v. Commissioner, supra at 84; Welch v.                 
         Helvering, supra at 115.  Accordingly, we find for respondent.               
              To reflect our disposition of the disputed issues,                      


                                                 Decision will be entered             
                                            for respondent.                           




























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