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FARRELL v. COMMISSIONER

Docket No. 24223-81.

46 T.C.M. 1290 (1983)

T.C. Memo. 1983-542

Paul Farrell and Rose Farrell v. Commissioner.

United States Tax Court.

Filed September 1, 1983.

Attorney(s) appearing for the Case

Edward R. Joyce, 317 N. 11th St., St. Louis, Mo., for the petitioners. Donald L. Wells, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1977 in the amount of $1,065. The sole issue presented for our decision is whether petitioners' farming operation was an "activity * * * not engaged in for profit" within the meaning of section 183(a) of the Internal Revenue Code of 1954.1

Findings of Fact

Some of...

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