OPINION
RAUM, Judge:
The Commissioner determined deficiencies in petitioner's 1980 and 1981 Federal income tax in the amounts of $3,680 and $12,696, respectively. The deficiencies for both years resulted from the disallowance of expense deductions taken by petitioner for the rental of a 53-foot powerboat known as the Americana. The case was submitted on the basis of a stipulation of facts.
During the years at issue, petitioner was a...
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