Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax of $5,173.89 for the year 1957. The sole issue presented is whether petitioner operated a dog kennel as a business during 1957.
Findings of Fact
Some of the facts have been stipulated and are so found.
Petitioner, an individual, filed his 1957 income tax return on a cash basis with the director of internal revenue at Pittsburgh...
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