MEMORANDUM OPINION
DEAN, Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax of $3,664 for the taxable year 1993. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues for decision are: (1) Whether petitioners' horse-related activities were engaged in for profit...
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