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SULLIVAN v. COMMISSIONER

Docket No. 3332-96.

76 T.C.M. 664 (1998)

T.C. Memo. 1998-367

James L. Sullivan and Dorothy B. Sullivan v. Commissioner.

United States Tax Court.

Filed October 8, 1998.

Attorney(s) appearing for the Case

Bruce Locke, Houston, Tex., for the petitioners. Roberta L. Shumway, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GALE, Judge:

Respondent determined a deficiency of $21,561.45 in petitioners' Federal income tax for taxable year 1992. The issue for decision is whether petitioners' horse breeding and showing activities constitute an "activity not engaged in for profit" within the meaning of section 183.1

FINDINGS OF FACT

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