Ruben v. Commissioner

BARNEY C. RUBEN AND ELEANOR RUBEN 1, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Ruben v. Commissioner

Docket No. 5788-82.

United States Tax Court

T.C. Memo 1986-260; 1986 Tax Ct. Memo LEXIS 348; 51 T.C.M. (CCH) 1268; T.C.M. (RIA) 86260;

June 24, 1986.

John P. Callahan, for the petitioners.

Rosa Berman, for the respondent.

CLAPP

MEMORANDUM FINDINGS OF FACT AND OPINION

CLAPP, Judge: Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year

Deficiency 2

1976

$28,323

1977

48,140

1978

35,567

The issue for decision is whether petitioners' horse operations constituted an…