Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rules 180, 181 and 182.
Respondent determined deficiencies of $1,634 and $1,535 in petitioner's Federal income tax for the taxable years 1984 and 1985, respectively.
The sole issue for decision is whether petitioner engaged in a horse raising/training/competition...
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