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SMITH v. COMMISSIONER

Docket No. 4395-66.

26 T.C.M. 1219 (1967)

T.C. Memo. 1967-241

Curtis C. Smith and Evelyn Smith v. Commissioner.

United States Tax Court.

Filed December 5, 1967.

Attorney(s) appearing for the Case

Robert M. Tyle, 1001-1003 Times Sq. Bldg., 45 Exchange St., Rochester, N. Y., for the petitioners. Leon M. Kerry, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1962, 1963, and 1964 in the amounts of $816.66, $915.82, and $857.79, respectively. Respondent disallowed losses and an investment credit claimed by petitioners in conjunction with the operation of a horse farm. The sole question before us is whether petitioners' operation...

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