Memorandum Opinion
KORNER, Judge:
For the years 1986 and 1987, respondent determined deficiencies of income tax against petitioner in the respective amounts of $7,686 and $5,924. The only issue we must decide is whether in those years petitioner was engaged in the enterprise of stock car racing with the actual and honest objective of making a profit, so as to entitle him to deduct from his income the net losses incurred from the enterprise in each year....
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