Pessin v. Commissioner
United States Tax Court
Petitioner, a veterinarian, during the taxable years 1965 and 1966 was in the business of breeding horses, trading in property rights in horses, and rendering advice in connection with the promotion of syndications of thoroughbred racehorses. During this period he assisted in three separate syndications for which he received nominations (breeding rights) in the stallions which had been syndicated.
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Petitioner, a veterinarian, during the taxable years 1965 and 1966 was in the business of breeding horses, trading in property rights in horses, and rendering advice in connection with the promotion of syndications of thoroughbred racehorses. During this period he assisted in three separate syndications for which he received nominations (breeding rights) in the stallions which had been syndicated. Held, (1) that petitioner received the nominations in question on the date of the effective syndications of the stallions involved; fair market value of such stallions determined; and (2) addition…
1Opinion of the Court
Withey, Judge:
Respondent determined deficiencies in petitioners’ income tax and additions to tax as follows:
Addition to tax sec. Taxable year Deficiency 6668(a) [1]
1965__$74,012.30 $3,700.62
1966_ 31, 940. 57 1, 597. 03
The issues presented for our consideration are:(1) Whether the receipt of the nominations by Dr. Pessin constituted taxable income to the extent of the fair market value of the nominations as determined by respondent; and(2) Whether petitioners are subject to the additions to tax for the taxable years 1965 and 1966 under section 6653(a), I.R.C. 1954.
FINDINGS OF FACT
All…
2Cases cited9 opinions
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