Legal Opinion

Duggar v. Commissioner

United States Tax Court

Decided November 9, 1978No. Docket No. 178-76Published

Under a three-part Cattle Management Agreement and Sublease, petitioner leased 40 brood cows. The purpose of the lease was to begin building a herd of Simmental cattle. Management Agreement One required petitioner to pay a lease fee and a fee for the maintenance and care of the leased cows. Under Management Agreement Two, petitioner paid a fee for the raising of his weaned female calves.

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Under a three-part Cattle Management Agreement and Sublease, petitioner leased 40 brood cows. The purpose of the lease was to begin building a herd of Simmental cattle. Management Agreement One required petitioner to pay a lease fee and a fee for the maintenance and care of the leased cows. Under Management Agreement Two, petitioner paid a fee for the raising of his weaned female calves. Held: Those expenditures associated with the leased brood cows were nondeductible capital expenditures. The agreement was in effect for the purchase of weaned calves. Held, further: Petitioner was a farmer…

1Opinion of the Court

Perry N. Duggar and Patricia J. Duggar, Petitioners v. Commissioner of Internal Revenue, Respondent

Duggar v. Commissioner

Docket No. 178-76

United States Tax Court

71 T.C. 147; 1978 U.S. Tax Ct. LEXIS 33;

November 9, 1978, Filed

Decision will be entered under Rule 155.

Under a three-part Cattle Management Agreement and Sublease, petitioner leased 40 brood cows. The purpose of the lease was to begin building a herd of Simmental cattle. Management Agreement One required petitioner to pay a lease fee and a fee for the maintenance and care of the leased cows. Under Management Agreement Two, petitioner…

2Cases cited5 opinions

  1. Maple Leaf Farms, Inc. v. CommissionerUnited States Tax Court · 1975
  2. Robert L. And Dorothy G. Maple v. Commissioner of Internal Revenue, William M. And Eleanor A. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  3. Wiener v. CommissionerUnited States Tax Court · 1972
  4. Duggar v. CommissionerUnited States Tax Court · 1978
  5. Welder v. United StatesDistrict Court, S.D. Texas · 1971

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