Farish v. Commissioner
United States Board of Tax Appeals
NONDEDUCTIBLE LOSSES. - During the taxable years petitioners were members of two partnerships, which were engaged in breeding polo ponies and race horses. On the facts, held that neither of such partnerships was carrying on a trade or business, and the losses sustained were not incurred in transactions entered into for profit, within the purview of section 23, Revenue Act of 1932.
1Opinion of the Court
*1118OPINION.
Hill:
During the taxable years 1932 and 1933 petitioner was a member of two partnerships known as the Huisache Stables and Farish, Wiess & Evans, respectively, each of which sustained a net loss in each of those years. Petitioner contends that he is entitled to deduct his distributive share of such net loss either as ordinary and necessary expenses paid or incurred in carrying on a trade or business, or as losses incurred in a trade or business and not compensated for by insurance or otherwise,, or as losses incurred in transactions entered into for profit, though not connected with…
2Cases cited3 opinions
- Thacher v. LoweDistrict Court, S.D. New York · 1922
- Wilson v. EisnerCourt of Appeals for the Second Circuit · 1922
- Plant v. WalshDistrict Court, D. Connecticut · 1922
3Cited by7 opinions
- Weir v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Farish v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1939
- Fields v. CommissionerUnited States Tax Court · 1981
- Cord v. CommissionerUnited States Board of Tax Appeals · 1938
- Farish v. CommissionerUnited States Board of Tax Appeals · 1937
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