Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By notice of deficiency dated April 1, 1987, respondent determined deficiencies in petitioners' Federal income tax for 1984 and 1985 in the amounts of $6,532.76 and $11,156.28, respectively.
The issues for decision are:
1. Whether petitioner's automobile sales activity and automobile racing activity are separate activities for purposes of section 183;
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