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DWYER v. COMMISSIONER

Docket Nos. 42696-86, 35795-87, 28400-88.

61 T.C.M. 2187 (1991)

T.C. Memo. 1991-123

Paul Dwyer and Janice L. Dwyer, et al. v. Commissioner.

United States Tax Court.

Filed March 19, 1991.

Attorney(s) appearing for the Case

Robert A. Wherry, Jr., 425 S. Cherry St., Denver, Colo., for the petitioners. Richard D. D'Estrada, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

During the years 1980 through 1986, petitioners deducted net losses and claimed investment credits associated with auto racing activities of petitioner Paul S. Dwyer, and petitioners' son, Clark Dwyer.

After concessions,1 the sole issues for decision are:

(1) Whether petitioners' auto racing activity in 1980 and 1981 was engaged in for profit. We hold that...

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