Memorandum Findings of Fact and Opinion
KORNER, Judge.
By a timely sent notice of deficiency, respondent determined deficiencies in petitioners' 1985 and 1986 Federal income tax of $4,897 and $6,228, respectively. The issues for decision are: (1) Whether petitioners' yacht-chartering activity was an activity not engaged in for profit; (2) whether petitioners placed their yacht in service in 1985; and (3) whether petitioners are entitled to an investment...
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