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SHANE v. COMMISSIONER

Docket No. 8409-94.

70 T.C.M. 1052 (1995)

T.C. Memo. 1995-504

Michael T. Shane v. Commissioner.

United States Tax Court.

Filed October 23, 1995.

Attorney(s) appearing for the Case

Charles C. Shelton, Baltimore, Md., and Evan Feldman, for the petitioner. Elizabeth S. Henn, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined deficiencies of $8,483 and $6,910 in petitioner's Federal income taxes for taxable years 1990 and 1991, respectively.

The sole issue for decision is whether petitioner's horseracing and horse-breeding activity was undertaken with the objective of making a profit within the meaning of section 1831 during the years at issue. We hold that it was...

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