Golanty v. Commissioner
United States Tax Court
Ps operated an Arabian horse-breeding venture. Over a number of years, they incurred substantial losses in such operation, and in no year did the operation make a profit. Ps had income from other sources which allowed them to sustain the losses. Held, based on all the facts and circumstances, including the tax benefit expected from the deduction of the losses, the horse-breeding activity was not conducted for profit within the meaning of sec. 183, I.R.C. 1954.
1Opinion of the Court
Simpson, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal income taxes of $12,180 for 1972 and $9,031 for 1973. The only issue for decision is whether the petitioners’ Arabian horse-breeding operation was an “activity * * * not engaged in for profit” within the meaning of section 183(a) of the Internal Revenue Code of 1954.1
FINDINGS OF 'FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners, Stanley A. Golanty and Lorriee M. Golanty, husband and wife, maintained their legal residence in Long Beach, Calif., at the time they filed…
2Cases cited13 opinions
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Allen v. CommissionerUnited States Tax Court · 1979
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Dunn v. CommissionerUnited States Tax Court · 1978
- Benz v. CommissionerUnited States Tax Court · 1974
8 more not listed; retrieve them via the Exa API.
3Cited by506 opinions
- Engdahl v. CommissionerUnited States Tax Court · 1979
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- Siegel v. CommissionerUnited States Tax Court · 1982
- Flowers v. CommissionerUnited States Tax Court · 1983
501 more not listed; retrieve them via the Exa API.