Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioners' 1978 and 1979 Federal income taxes in the amounts of $15,439 and $18,111, respectively. The issues for decision are: (1) whether petitioners' rental of real property was an activity engaged in for profit; (2) whether petitioners' horse operations constituted an activity engaged in for profit;
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