Anthony Imbesi and Hazel Imbesi v. Commissioner of Internal Revenue

FREEDMAN, Circuit Judge.

The taxpayer 1 challenges the decision of the Tax Court sustaining the Commissioner’s determination of income tax deficiencies totalling $177,452.44 which resulted from the disallowance of losses incurred in the years 1955 through 1959 in the breeding, training and exhibition of English Setter dogs and the breeding, training and racing of horses. The Tax Court in effect held that these activities of the taxpayer did not constitute a trade or business under § 165(c) (1) or transactions entered into for profit under § 165 (c) (2) of the Internal Revenue Code of 1954, 2…