Litzenberg v. Commissioner
United States Tax Court
David Litzenberg, in 1981, accepted five horses from a neighbor in satisfaction of a $74,994 debt. Though Litzenberg raced and bred the horses, he lost money; one of the horses was destroyed. The Service determined deficiencies with respect to David Litzenberg's 1982 through 1984 taxes, contending Litzenberg's horse breeding activities were not engaged in with a profit motive. Accordingly, the Service contended that Litzenberg could not deduct horse breeding expenses.
Read the full summary
David Litzenberg, in 1981, accepted five horses from a neighbor in satisfaction of a $74,994 debt. Though Litzenberg raced and bred the horses, he lost money; one of the horses was destroyed. The Service determined deficiencies with respect to David Litzenberg's 1982 through 1984 taxes, contending Litzenberg's horse breeding activities were not engaged in with a profit motive. Accordingly, the Service contended that Litzenberg could not deduct horse breeding expenses. The Service also disputed Litzenberg's claimed casualty loss for the destruction of a horse. Litzenberg petitioned the Tax…
1Opinion of the Court
DAVID LITZENBERG AND PAT LITZENBERG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Litzenberg v. Commissioner
Docket No. 11406-87
United States Tax Court
T.C. Memo 1988-482; 1988 Tax Ct. Memo LEXIS 555; 56 T.C.M. (CCH) 413; T.C.M. (RIA) 88482;
October 4, 1988
David Litzenberg, in 1981, accepted five horses from a neighbor in satisfaction of a $74,994 debt. Though Litzenberg raced and bred the horses, he lost money; one of the horses was destroyed. The Service determined deficiencies with respect to David Litzenberg's 1982 through 1984 taxes, contending Litzenberg's horse breeding…
2Cases cited16 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Wilkinson v. CommissionerUnited States Tax Court · 1979
- Seaboard Commercial Corp. v. CommissionerUnited States Tax Court · 1957
- Cloes v. CommissionerUnited States Tax Court · 1982
- Commissioner of Internal Revenue v. SpreckelsCourt of Appeals for the Ninth Circuit · 1941
11 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Renee Vento v. CommissionerUnited States Tax Court · 2019