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APPLEY v. COMMISSIONER

Docket No. 2242-77.

39 T.C.M. 386 (1979)

T.C. Memo. 1979-433

Lawrence A. Appley and Estate of Ruth W. Appley, Deceased, Lawrence A. Appley, Executor v. Commissioner.

United States Tax Court.

Filed October 23, 1979.

Attorney(s) appearing for the Case

Sterling L. Weaver, for the petitioners. David R. Smith, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

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

          Year            Deficiency

          1972 ........... $35,258
          1973 ...........  25,690
          1974 ...........  34,812

The only issue for decision is whether a Morgan horse farm operated by petitioners as a small business corporation constituted a trade or business or...

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