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DUNN v. COMMISSIONER

Docket No. 114-76.

70 T.C. 715 (1978)

HERBERT A. DUNN AND GEORGIA E. DUNN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 21, 1978.

Attorney(s) appearing for the Case

Robert M. Tyle, for the petitioners.

Anthony M. Bruce, for the respondent.

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

    Year                             Deficiency
    1970 --------------------------- $50,531.75
    1971 -----------------------------21,618.10

The issues remaining for our decision are: (1) Whether petitioner Herbert Dunn was engaged in the trade or business of harness horse racing...

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