Duggar v. Commissioner
United States Tax Court
Under a three-part Cattle Management Agreement and Sublease, petitioner leased 40 brood cows. The purpose of the lease was to begin building a herd of Simmental cattle. Management Agreement One required petitioner to pay a lease fee and a fee for the maintenance and care of the leased cows. Under Management Agreement Two, petitioner paid a fee for the raising of his weaned female calves.
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Under a three-part Cattle Management Agreement and Sublease, petitioner leased 40 brood cows. The purpose of the lease was to begin building a herd of Simmental cattle. Management Agreement One required petitioner to pay a lease fee and a fee for the maintenance and care of the leased cows. Under Management Agreement Two, petitioner paid a fee for the raising of his weaned female calves. Held: Those expenditures associated with the leased brood cows were nondeductible capital expenditures. The agreement was in effect for the purchase of weaned calves. Held, further: Petitioner was a farmer…
1Opinion of the Court
Irwin, Judge:
Respondent determined deficiencies in petitioners’ income tax for the calendar years 1972 and 1973 in the amounts $6,054.85 and $855.86, respectively. The only issue remaining for our decision is whether certain payments made by petitioners for the leasing, maintenance, and care of cows, and for the maintenance and care of their calves represent currently deductible business expenses or expenditures which are capital in nature.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts along with attached exhibits are incorporated herein by this reference.
Peti…
2Cases cited4 opinions
- Maple Leaf Farms, Inc. v. CommissionerUnited States Tax Court · 1975
- Robert L. And Dorothy G. Maple v. Commissioner of Internal Revenue, William M. And Eleanor A. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Wiener v. CommissionerUnited States Tax Court · 1972
- Welder v. United StatesDistrict Court, S.D. Texas · 1971
3Cited by9 opinions
- La Musga v. CommissionerUnited States Tax Court · 1982
- Ellis v. CommissionerUnited States Tax Court · 1984
- Vinson v. CommissionerUnited States Tax Court · 1979
- Borkowski v. CommissionerUnited States Tax Court · 1982
- Cameron v. CommissionerUnited States Tax Court · 1982
4 more not listed; retrieve them via the Exa API.