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  5. 47 T.C.M. 991 (1984)
 

ELLIS v. COMMISSIONER

Docket No. 9666-80.

47 T.C.M. 991 (1984)

T.C. Memo. 1984-50

Robert V. and Betty J. Ellis v. Commissioner.

United States Tax Court.

Filed January 31, 1984.

Attorney(s) appearing for the Case

George S. Bennett and John T. Kay, Jr., for the petitioners. Robert J. Kastl, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency of $2,883.59 in petitioners' Federal income tax for the taxable year 1977. The issues for our decision are:

1. Whether petitioners' operation of Round Top, a "horse farm," constitutes "an activity not engaged in for profit" within the meaning of section 183;1 and

2. If Round Top is found to be an activity engaged in for profit...

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