George W. Gagnon; Margaret L. Gagnon, Petitioners-appellants, v. Commissioner of Internal Revenue, Respondent-appellee, 124 F.3d 211 (9th Cir. 1997)

MEMORANDUM^* 

George W. and Margaret L. Gagnon appeal pro se the Tax Court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of federal income tax deficiencies for the tax years 1991, 1992, and 1993. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review for clear error the tax court's finding that a taxpayer is not engaged in an activity primarily for profit under 26 U.S.C. § 183. See Wolf v. Commissioner, 4 F.3d 709, 712 (9th Cir. 1993). We affirm.

We conclude that, viewed in its entirety, the Tax Court's finding that the Gagnons failed to establish a bona fide profit motive in the Gull Cottage Nursery was not clearly erroneous. See id. at 713.

We also conclude that the Gagnons' remaining contentions are without merit.

AFFIRMED.