Engdahl v. Commissioner
United States Tax Court
Petitioners operated an American saddle-bred horse-breeding venture. Petitioners did most of the work on their horse ranch themselves, and did not use the horses or the ranch for personal pleasure. Petitioners intended to make a profit to supplement their retirement income, but, over a number of years, they incurred an uninterrupted series of losses. Petitioners had income from other sources against which they applied the losses.
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Petitioners operated an American saddle-bred horse-breeding venture. Petitioners did most of the work on their horse ranch themselves, and did not use the horses or the ranch for personal pleasure. Petitioners intended to make a profit to supplement their retirement income, but, over a number of years, they incurred an uninterrupted series of losses. Petitioners had income from other sources against which they applied the losses. Held, on the facts, the horse-breeding operation was an activity engaged in for profit under sec. 183, I.R.C. 1954.
1Opinion of the Court
Hall, Judge:
Respondent determined deficiencies in petitioners’ income tax as follows:
Year Deficiency
1971 . $9,471.84
1972 ..... 6,801155
1973 . 9,193.55
The issue for decision is whether petitioners’ horse-breeding operation was an “activity * * * not engaged in for profit” within the meaning of section 183(a).1 Our determination as to this issue will automatically resolve whether petitioners are entitled to investment credits for assets purchased for their horse-breeding operation.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
At the time of filing their…
2Cases cited14 opinions
- Golanty v. CommissionerUnited States Tax Court · 1979
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Allen v. CommissionerUnited States Tax Court · 1979
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Dunn v. CommissionerUnited States Tax Court · 1978
9 more not listed; retrieve them via the Exa API.
3Cited by355 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Brannen v. CommissionerUnited States Tax Court · 1982
- Siegel v. CommissionerUnited States Tax Court · 1982
- Beck v. CommissionerUnited States Tax Court · 1985
- Flowers v. CommissionerUnited States Tax Court · 1983
350 more not listed; retrieve them via the Exa API.