Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners' Federal income taxes of $1,117.00 for 1976 and $4,187.00 for 1977. The issues for decision are: (1) Whether the operation of the petitioners' farm was an "activity * * * not engaged in for profit" within the meaning of section 183(a) of the Internal Revenue Code of 1954;
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