Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a statutory notice of deficiency dated June 19, 1986, determined deficiencies in the 1982 and 1983 income taxes of petitioners, Benjamin H. Ewing and Doris J. Ewing, in the respective amounts of $21,339.81 and $23,481.33. The deficiencies resulted from the disallowance of certain expenses and deductions purportedly associated with petitioners' quarter horse breeding activity. The sole...
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