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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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Last modified: March 27, 2008