Gamble v. Commissioner
United States Tax Court
Among his other business and investment interests, T was engaged in the business of racing thoroughbred horses. He purchased a pregnant broodmare for use in that business. The colt that was thereafter born had considerable promise as a racehorse in view of its bloodlines. T intended to exploit the colt either by selling it, racing it (after training which ordinarily does not begin until about 18 months after birth), or in some other manner.
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Among his other business and investment interests, T was engaged in the business of racing thoroughbred horses. He purchased a pregnant broodmare for use in that business. The colt that was thereafter born had considerable promise as a racehorse in view of its bloodlines. T intended to exploit the colt either by selling it, racing it (after training which ordinarily does not begin until about 18 months after birth), or in some other manner. His intention to sell did not predominate over his other possible objectives. When the colt was about 16 months old, and had neither been trained nor in…
1Opinion of the Court
Raum, Judge:
The Commissioner determined a deficiency of $62,256.60 in petitioners’ 1971 income tax. At issue are first, whether petitioners realized ordinary income or capital gain from the sale of a yearling colt, and second, the proper cost basis of the colt.
FINDINGS OF FACT
The parties have filed a stipulation of facts and a supplemental stipulation of facts, both of which, together with the exhibits attached thereto, are incorporated herein by this reference.
Petitioners Launce E. Gamble and Joan L. Gamble, husband and wife, timely filed a joint Federal income tax return for 1971. At the…
2Cases cited26 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- United States v. Bennett (Two Cases). Finch v. Arnold, Acting Collector of Internal Revenue (Two Cases). Birkbeck v. Thomas. Ritchie v. ThomasCourt of Appeals for the Fifth Circuit · 1951
- Albright v. United StatesCourt of Appeals for the Eighth Circuit · 1949
- Bynum v. CommissionerUnited States Tax Court · 1966
21 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Buono v. CommissionerUnited States Tax Court · 1980
- Guardian Indus. Corp. v. CommissionerUnited States Tax Court · 1991
- Greer v. CommissionerUnited States Tax Court · 1978
- First Northwest Industries, Inc. v. CommissionerUnited States Tax Court · 1978
- Buono v. CommissionerUnited States Tax Court · 1980
6 more not listed; retrieve them via the Exa API.