Houchins v. Commissioner
United States Tax Court
Petitioner Marion O. Houchins entered into a cattle-breeding program marketed by two corporations, Y and Z, which were under the common control of X, an individual. Pursuant to this transaction, petitioner executed a sales agreement, promissory note, management agreement, and security agreement. Under the sales agreement, petitioner agreed to purchase four cows from Y for a total purchase price of $ 40,000. The cows did not have a fair market value in excess of $ 2,500 each.
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Petitioner Marion O. Houchins entered into a cattle-breeding program marketed by two corporations, Y and Z, which were under the common control of X, an individual. Pursuant to this transaction, petitioner executed a sales agreement, promissory note, management agreement, and security agreement. Under the sales agreement, petitioner agreed to purchase four cows from Y for a total purchase price of $ 40,000. The cows did not have a fair market value in excess of $ 2,500 each. The management agreement provided that for a period of approximately 6 years, Z would manage and maintain the four cows…
1Opinion of the Court
Wiles, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes:
Year Deficiency
1975 .$8,431
1976 . 6,498
1977 . 5,079
The issue for decision is whether petitioners are entitled to miscellaneous deductions claimed in connection with an investment in a cattle-breeding program.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Marion O. Houchins (hereinafter petitioner) and June A. Houchins, husband and wife, resided in Orlando, Fla., when they filed their 1975, 1976, and 1977 joint Federal income tax returns with the Office of the…
2Cases cited20 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
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3Cited by68 opinions
- Waddell v. CommissionerUnited States Tax Court · 1986
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- Brown v. CommissionerUnited States Tax Court · 1985
- Leahy v. CommissionerUnited States Tax Court · 1986
- Capek v. CommissionerUnited States Tax Court · 1986
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