Sabelis v. Commissioner
United States Tax Court
Petitioners, during the years in issue, owned property known as Circle S Breeding Farm. There were two residences on the farm. One was occupied by petitioners and their daughters and the other by the mother and sister of Theodore Sabelis, one of the petitioners who is sometimes herein referred to as the husband.
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Petitioners, during the years in issue, owned property known as Circle S Breeding Farm. There were two residences on the farm. One was occupied by petitioners and their daughters and the other by the mother and sister of Theodore Sabelis, one of the petitioners who is sometimes herein referred to as the husband. The property other than the residences was used partly to enable Karen, older daughter of the petitioners, to pursue 4-H projects, and partly (with the help of Karen) for the breeding, training, and boarding of horses, and the giving of riding lessons. The funds for the purchase of…
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in income tax of petitioners as follows:
year Deficiency
1955_$484. 72
1956_ 488.91
1957_ 584. 96
The basic issues presented are: (1) Whether, during the years in question, petitioners in operating Circle S Breeding Farm were operating a trade or business, and (2) if they were operating a trade or business, the amounts of deductions allowable in determining net losses for said years.
FINDINGS OF FACT.
Petitioners, husband and wife, filed their joint income tax returns for the years 1955,1956, and 1957 with the district director of internal revenue,…
2Cases cited1 opinion
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
3Cited by56 opinions
- Golanty v. CommissionerUnited States Tax Court · 1979
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Allen v. CommissionerUnited States Tax Court · 1979
- Dunn v. CommissionerUnited States Tax Court · 1978
- Benz v. CommissionerUnited States Tax Court · 1974
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