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DAUGHERTY v. COMMISSIONER

Docket No. 17982-81.

45 T.C.M. 1224 (1983)

T.C. Memo. 1983-188

William G. Daugherty and Helen G. Daugherty v. Commissioner.

United States Tax Court.

Filed April 5, 1983.

Attorney(s) appearing for the Case

Samuel G. Brundage, 47 S. Fitzhugh St., Rochester, N.Y., for the petitioners. Michael Sheeley, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined deficiencies in petitioners' taxes for 1976, 1977, and 1978 of $4,383, $5,853, and $8,141, respectively. The question presented is whether petitioners' farming activity with respect to those years was "an activity not engaged in for profit" within the meaning of section 183.1

Findings of Fact...

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