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DAVIDSON v. COMMISSIONER

Docket No. 8766-77.

82 T.C. 434 (1984)

ELI DAVIDSON AND LILLIAN DAVIDSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 8, 1984.

Attorney(s) appearing for the Case

John E. O'Brien, for the petitioners.

Evelyn B. Brennan, for the respondent.

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1973 and 1974, in the amounts of $5,628.83 and $3,465, respectively. After a concession by petitioners, the issues for decision1 are as follows:

(1) Whether petitioners' boat was used primarily for the furtherance of petitioner-husband's trade or business, within the meaning of section 274(a).2

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