Simpson, Judge: The Commissioner determined deficiencies in the petitioners’ Federal income taxes of $12,180 for 1972 and $9,031 for 1973. The only issue for decision is whether the petitioners’ Arabian horse-breeding operation was an “activity * * * not engaged in for profit” within the meaning of section 183(a) of the Internal Revenue Code of 1954. 1 <p "b…
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