Purdey v. United States

OPINION

MARGOLIS, Judge.

In this tax refund action, currently before the Court on plaintiffs’ and defendant’s cross-motions for summary judgment, plaintiffs claim that certain deductions allowed under 26 U.S.C. § 183 are also permitted in calculating plaintiffs’ Alternative Minimum Tax.

FACTS

During the years 1984, 1985, 1986, 1988, and 1989 (hereinafter “tax years at issue”), plaintiffs, William A. Purdey and Frances C. Purdey, conducted thoroughbred breeding and racing activities at their ranch in Colts Neck, New Jersey. These activities included keeping and maintaining stallions, broodmares,…