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POWELL v. COMMISSIONER

Docket No. 14749-82.

52 T.C.M. 163 (1986)

T.C. Memo. 1986-369

Norman E. Powell and Barbara Powell v. Commissioner.

United States Tax Court.

Filed August 11, 1986.

Attorney(s) appearing for the Case

Kenneth Zuckerbrot, 260 Madison Ave., New York, N.Y., Felice F. Mischele, 40 West 57th Street, New York, N.Y. 10019, and Robert J. Preminger, for the petitioners. Michael N. Balsamo and Gregg M. Weiss, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency of $78,090.90 in petitioners' 1978 joint Federal income tax. The primary issue for decision is whether petitioners' license activities with respect to "The Ultrasonic Plaque Control Instrument" were activities not engaged in for profit within the meaning of section 183.1

Findings of Fact

Some of the facts have been stipulated...

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