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KEANINI v. COMMISSIONER

Docket No. 5663-87.

94 T.C. 41 (1990)

SAMUEL KEANINI AND MOANIKIALA JELLINGER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 30, 1990.

Attorney(s) appearing for the Case

Linnel T. Nishioka, for the petitioners.

Jonathan J. Ono, for the respondent.

NIMS, Chief Judge:

Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $3,964 and $3,875.55 for 1982 and 1983, respectively. (All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.)

The issues for decision are whether petitioners (1) engaged in dog breeding and grooming...

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