John T. Steen and Nell D. Steen v. Commissioner of Internal Revenue

Treating the main house, pool house and guest house on his River ranch as farm buildings, Steen claimed a deduction for depreciation in the years 1968 and 1969. The Commissioner disallowed the deduction, the Tax Court upheld the Commissioner, 61 T.C. 298, and Steen appealed. We affirm.

The houses were on the ranch at the time of its purchase by Steen. The main house was put to three uses: Steen and his foreman would sometimes meet briefly on Steen’s weekend visits to the ranch; Steen and his wife would occasionally stay overnight on his weekend visits; and Steen entertained business and social…