MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge:
Respondent determined deficiencies with respect to petitioners' Federal income tax of $183,774 for 2000 and $197,473 for 2001. The issues for decision are:
(1) Whether petitioners' exotic animal breeding activity for 2000 and 2001 constituted an activity engaged in for profit within the meaning of section 183;
(2) if petitioners were engaged in an activity...
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