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NICHOLS v. COMMISSIONER

Docket No. 21922-88.

60 T.C.M. 1039 (1990)

T.C. Memo. 1990-546

David E. Nichols and Teresa L. Deese, formerly Teresa L. Nichols, now Teresa D. Fritch v. Commissioner.

United States Tax Court.

Filed October 22, 1990.

Attorney(s) appearing for the Case

K. Patrick Neill, for the petitioners. Karen E. Stratton and Ralph W. Jones, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined Federal income tax deficiencies for 1983 and 1984 in the amounts of $11,586.20 and $15,428.00, respectively. The deficiencies were solely attributable to the disallowance of petitioners' claimed losses from an automobile racing activity. The issue presented for our consideration is whether the automobile racing activity constituted an activity not engaged in for profit within the...

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