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ALLEN v. COMMISSIONER

Docket No. 5435-76.

72 T.C. 28 (1979)

TRUETT E. ALLEN AND BARBARA ALLEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 2, 1979.

Attorney(s) appearing for the Case

F. L. Dougan and Vincent J. Boyd, for the petitioners.

Joan Ronder Domike, for the respondent.

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income taxes of $1,376 for 1971 and $3,209 for 1972. The petitioners have conceded certain issues. The only issue left for decision is whether the petitioners operated their lodge as an "activity * * * not engaged in for profit" within the meaning of section 183(a), I.R.C. 1954.1

FINDINGS OF FACT...

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