Gamble v. Commissioner
United States Tax Court
Among his other business and investment interests, T was engaged in the business of racing thoroughbred horses. He purchased a pregnant broodmare for use in that business. The colt that was thereafter born had considerable promise as a racehorse in view of its bloodlines. T intended to exploit the colt either by selling it, racing it (after training which ordinarily does not begin until about 18 months after birth), or in some other manner.
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Among his other business and investment interests, T was engaged in the business of racing thoroughbred horses. He purchased a pregnant broodmare for use in that business. The colt that was thereafter born had considerable promise as a racehorse in view of its bloodlines. T intended to exploit the colt either by selling it, racing it (after training which ordinarily does not begin until about 18 months after birth), or in some other manner. His intention to sell did not predominate over his other possible objectives. When the colt was about 16 months old, and had neither been trained nor in…
1Opinion of the Court
Launce E. Gamble and Joan L. Gamble, Petitioners v. Commissioner of Internal Revenue, Respondent
Gamble v. Commissioner
Docket No. 1617-76
United States Tax Court
68 T.C. 800; 1977 U.S. Tax Ct. LEXIS 58;
August 30, 1977, Filed
Decision will be entered under Rule 155.
Among his other business and investment interests, T was engaged in the business of racing thoroughbred horses. He purchased a pregnant broodmare for use in that business. The colt that was thereafter born had considerable promise as a racehorse in view of its bloodlines. T intended to exploit the colt either by selling it, racing it…
2Cases cited27 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- United States v. Bennett (Two Cases). Finch v. Arnold, Acting Collector of Internal Revenue (Two Cases). Birkbeck v. Thomas. Ritchie v. ThomasCourt of Appeals for the Fifth Circuit · 1951
- Albright v. United StatesCourt of Appeals for the Eighth Circuit · 1949
- Bynum v. CommissionerUnited States Tax Court · 1966
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