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BURGER v. COMMISSIONER

Docket No. 11731-83.

50 T.C.M. 1266 (1985)

T.C. Memo. 1985-523

Thomas C. Burger and Marian E. Burger v. Commissioner.

United States Tax Court.

Filed October 7, 1985.

Attorney(s) appearing for the Case

David E. Price and Steven C. Bradley, 231 N. Hwy., Jasper, Ind., for petitioners. Brett J. Miller and Reid M. Huey, for respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for 1978, 1979 and 1980 in the following amounts:

       Year          Deficiency

       1978......... $24,043.44
       1979......... $30,553.31
       1980......... $29,300.87

After concessions, the issues for decision are (1) whether petitioners' dog breeding activity was an "activity not engaged in...

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