Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies of $2,932 and $3,333 in petitioners' Federal income taxes for 1984 and 1985. The sole issue for our decision is whether petitioners operated their dog kennel with an actual and honest profit objective.
Findings...
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