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BRANNON v. COMMISSIONER

Docket No. 22025-97.

79 T.C.M. 1610 (2000)

T.C. Memo. 2000-76

Sandra J. Brannon v. Commissioner.

United States Tax Court.

Filed March 6, 2000.

Attorney(s) appearing for the Case

J. Raymond Karam, San Antonio, Texas, for the petitioner. Elizabeth A. Owen, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

Respondent determined deficiencies of $2,974 and $1,562 in Federal income taxes and penalties under section 6662(a)1 of $595 and $312, respectively, for petitioner's 1993 and 1994 tax years.

The issues for decision are: (1) Whether a horse breeding activity conducted by petitioner was an activity not engaged in for profit under section 183(a); (2) alternatively, whether...

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