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UNDERWOOD v. COMMISSIONER

Docket No. 4507-88.

58 T.C.M. 731 (1989)

T.C. Memo. 1989-625

Edward A. Underwood and Irene E. Underwood v. Commissioner.

United States Tax Court.

Filed November 20, 1989.

Attorney(s) appearing for the Case

David S. Lee and Lage E. Anderson, 216 Park Rd., Burlingame, Calif., for the petitioners. Patricia Montero, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined income tax deficiencies for 1981, 1984, and 1985 in the amounts of $2,624, $8,675, and $4,871, respectively. The deficiencies are attributable to petitioners' boat chartering activity. In this opinion we consider the following issues: (1) Whether petitioners' activity was not engaged in for profit; (2) whether petitioners' charter boat was placed in service in 1984; and (3) whether...

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