Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined deficiencies in petitioner's 1981 and 1982 Federal income taxes in the amounts of $1,387 and $2,173, respectively. After concessions, the sole issue for our determination is whether petitioner's golfing activity was an "activity not engaged in for profit" within the meaning of section 183.
Findings of Fact
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