Watson v. Commissioner
United States Tax Court
1. Petitioner's fur trading activity was a business, not a hobby. 2. Furs sent by petitioner to Seattle Fur Exchange for sale on consignment were includible in petitioner's inventory. 3. Petitioner failed to prove error in respondent's determination of value of the inventories. 4. Petitioner failed to prove that he was entitled to deduct business expenses in excess of those allowed by respondent. 5. Deficiencies in petitioner's tax liability for the years 1978 and 1979 were…
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1. Petitioner's fur trading activity was a business, not a hobby. 2. Furs sent by petitioner to Seattle Fur Exchange for sale on consignment were includible in petitioner's inventory. 3. Petitioner failed to prove error in respondent's determination of value of the inventories. 4. Petitioner failed to prove that he was entitled to deduct business expenses in excess of those allowed by respondent. 5. Deficiencies in petitioner's tax liability for the years 1978 and 1979 were due to fraud.
1Opinion of the Court
ALTON DANIEL WATSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
Watson v. Commissioner
Docket No. 27915-85.
United States Tax Court
T.C. Memo 1988-29; 1988 Tax Ct. Memo LEXIS 29; 54 T.C.M. (CCH) 1601; T.C.M. (RIA) 88029;
January 27, 1988.
1. Petitioner's fur trading activity was a business, not a hobby.
2. Furs sent by petitioner to Seattle Fur Exchange for sale on consignment were includible in petitioner's inventory.
3. Petitioner failed to prove error in respondent's determination of value of the inventories.
4. Petitioner failed to prove that he was entitled to deduct business…
2Cases cited14 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Stone v. CommissionerUnited States Tax Court · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Beaver v. CommissionerUnited States Tax Court · 1970
- Otsuki v. CommissionerUnited States Tax Court · 1969
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- Stewart v. Comm'rUnited States Tax Court · 2010
- Cook v. CommissionerUnited States Tax Court · 1991
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