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SMITH v. COMMISSIONER

Docket No. 29098-90.

65 T.C.M. 2289 (1993)

T.C. Memo. 1993-140

Kenneth A. Smith and Jill M. Smith v. Commissioner.

United States Tax Court.

Filed April 5, 1993.

Attorney(s) appearing for the Case

D. James Manning, P.O. Box 4167, 125 N. Garfield, Pocatello, Id., for the petitioners. Mary P. Kimmel, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for 1982, 1985, 1986, and 1987 of $41,012.50, $24,439.46, $58,425.04, and $62,716.16, respectively.

The sole issue1 for decision is whether petitioners' horsebreeding activity during the taxable years 1985, 1986, and 1987 constituted an activity "not engaged in for profit" within the meaning...

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