Memorandum Findings of Fact and Opinion
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986.
Respondent determined a deficiency in income tax for the taxable year 1983 in the amount of $6,531.00. The issues for decision are: (1) whether petitioner's car racing activity was engaged in for...
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