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CARSON v. COMMISSIONER

Docket No. 39310-87.

60 T.C.M. 870 (1990)

T.C. Memo. 1990-508

Morris E. Carson and Betty F. Carson v. Commissioner.

United States Tax Court.

Filed September 24, 1990.

Attorney(s) appearing for the Case

C. Richard Davis, 1011 E. Main St., Richmond, Va., for the petitioners. Deborah C. Stanley, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $2,562, $4,282, and $2,425 for taxable years 1984, 1985, and 1986, respectively. The sole issue for decision is whether petitioners' dog breeding activity was engaged in for profit, within the meaning of section 183(a).1

Findings of Fact

Some of the facts have been stipulated...

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