Godfrey v. Commissioner
United States Tax Court
1. Held, that losses which the principal petitioner incurred for all the taxable years in attempting to build up a herd of cattle by the natural increase process, with the hope that the herd would eventually attain sufficient size to produce profit, are not deductible as losses incurred in a "business," under section 165(c)(1) of the 1954 Code. 2. Held, that none of the various expenditures which the principal petitioner made in connection with two Florida real estate…
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1. Held, that losses which the principal petitioner incurred for all the taxable years in attempting to build up a herd of cattle by the natural increase process, with the hope that the herd would eventually attain sufficient size to produce profit, are not deductible as losses incurred in a "business," under section 165(c)(1) of the 1954 Code. 2. Held, that none of the various expenditures which the principal petitioner made in connection with two Florida real estate projects is deductible as nonbusiness expenses under section 212(2) of the 1954 Code. Commissioner's determinations as to…
1Opinion of the Court
Edward R. Godfrey and Georgia G. Godfrey v. Commissioner.
Godfrey v. Commissioner
Docket No. 87061.
United States Tax Court
T.C. Memo 1963-1; 1963 Tax Ct. Memo LEXIS 343; 22 T.C.M. (CCH) 1; T.C.M. (RIA) 63001;
January 2, 1963
1. Held, that losses which the principal petitioner incurred for all the taxable years in attempting to build up a herd of cattle by the natural increase process, with the hope that the herd would eventually attain sufficient size to produce profit, are not deductible as losses incurred in a "business," under section 165(c)(1) of the 1954 Code.
2. Held, that none of the various…
2Cases cited11 opinions
- Henry P. White and Estate of Nancy A. White, Deceased, T. Leo Sullivan, Administrator, C.T.A. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
- Thacher v. LoweDistrict Court, S.D. New York · 1922
- Louisiana Land & Exp. Co. v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1947
- Shainberg v. CommissionerUnited States Tax Court · 1959
6 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Chevy Chase Land Co. v. CommissionerUnited States Tax Court · 1979
- Chevy Chase Land Co. v. CommissionerUnited States Tax Court · 1979
- Pickering v. CommissionerUnited States Tax Court · 1979