Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year ending December 31, 1964, in the amount of $7,954.49.
The sole issue for decision is whether petitioners' activity of raising and breeding horses constituted a trade or business in the year 1967. If we make a determination that the horse raising and breeding activity constitutes a trade or business, the...
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