Lockhart v. Commissioner
United States Tax Court
1. "Hobby losses" from operation of a ranch were properly disallowed, sec. 270, I.R.C. 1954. 2. Constitutionality of this section upheld. 3. Disallowance of depreciation deduction sustained. Petitioner failed to take into account any salvage value or to show error in respondent's determination.
1Opinion of the Court
Train, Judge:
The respondent determined deficiencies in petitioner’s income tax for the years 1952 and 1954 in the amounts of $206,024.50 and $303,970.93, respectively.
The issues for decision are:(1) Whether petitioner’s deductions arising from the operation of a ranch in excess of petitioner’s gross income from the ranch plus $50,000 per year plus specially treated deductions were properly disallowed under section 270 of the Internal Revenue Code of 1954; and(2) Whether depreciation claimed by the petitioner on two airplanes is allowable.
FINDINGS OF FACT
Some of the facts have been stipulated…
2Cases cited11 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- White v. United StatesSupreme Court of the United States · 1938
- Helvering v. Independent Life InsuranceSupreme Court of the United States · 1934
- Commissioner v. SullivanSupreme Court of the United States · 1958
- Stanton v. Baltic Mining Co.Supreme Court of the United States · 1916
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Nammack v. CommissionerUnited States Tax Court · 1971
- Cottrell v. CommissionerUnited States Tax Court · 1970
- Covered Wagon, Inc. v. CommissionerUnited States Tax Court · 1965
- Beauchamp & Brown Groves Co. v. CommissionerUnited States Tax Court · 1965
- Borge v. CommissionerUnited States Tax Court · 1967
3 more not listed; retrieve them via the Exa API.