Hancock v. Commissioner
United States Tax Court
During 1953 petitioners sold certain cattle which had been held by them for more than 12 but less than 25 months as part of their breeding herd, but which had been culled from that herd because of the development of undesirable characteristics which made them unsuitable for breeding purposes.
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During 1953 petitioners sold certain cattle which had been held by them for more than 12 but less than 25 months as part of their breeding herd, but which had been culled from that herd because of the development of undesirable characteristics which made them unsuitable for breeding purposes. Held, at the time of their sale those cattle were held for breeding purposes within the meaning of section 117(j)(1) of the 1939 Code, thus entitling petitioners to treat the gains realized thereon as long-term capital gains.
1Opinion of the Court
L. D. Hancock and Elaine Hancock, Petitioners, v. Commissioner of Internal Revenue, Respondent
Hancock v. Commissioner
Docket No. 66706
United States Tax Court
31 T.C. 752; 1959 U.S. Tax Ct. LEXIS 262;
January 21, 1959, Filed
Decision will be entered under Rule 50.
During 1953 petitioners sold certain cattle which had been held by them for more than 12 but less than 25 months as part of their breeding herd, but which had been culled from that herd because of the development of undesirable characteristics which made them unsuitable for breeding purposes. Held, at the time of their sale those cattle…
Also in this document: Dissent.
2Cases cited10 opinions
- McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Fox v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
- Fox v. CommissionerUnited States Tax Court · 1951
- McDonald v. CommissionerUnited States Tax Court · 1955
- Robert B. Gotfredson and Charlotte B. Gotfredson v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
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