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MAGIN v. COMMISSIONER

Docket No. 23927-82.

50 T.C.M. 208 (1985)

T.C. Memo. 1985-304

Morris N. Magin and Janice Magin v. Commissioner.

United States Tax Court.

Filed June 25, 1985.

Attorney(s) appearing for the Case

Jeffrey A. King, 2071 Main St., Sarasota, Fla., for the petitioners. James W. Clark, for the respondent.

Memorandum Findings of Fact and Opinion

NIMS, Judge:

Respondent determined a deficiency of $20,464 in petitioners' 1977 Federal income tax.

The issues for decision are: (1) whether Morris N. Magin and Janice Magin (petitioners) were engaged in a bona fide business activity of television program distribution; (2) if so, whether petitioners' activity constituted an activity engaged in for profit under...

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