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ZWICKY v. COMMISSIONER

Docket No. 17235-83.

48 T.C.M. 1025 (1984)

T.C. Memo. 1984-471

John R. Zwicky and Kathleen M. Zwicky v. Commissioner.

United States Tax Court.

Filed September 4, 1984.

Attorney(s) appearing for the Case

Steven C. Bahls, 825 N. Jefferson St., Milwaukee, Wis. 53202, for the petitioner. Mark J. Miller, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

By statutory notice of deficiency dated April 4, 1983, respondent determined deficiencies in petitioners' Federal income tax liabilities for 1979 and 1980 in the amounts of $4,998.14 and $2,984.00, respectively.

The issues for decision are whether petitioners' fishing boat charter service was an activity engaged in for profit, and whether petitioners are entitled to an investment tax credit for...

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