Sheridan v. Commissioner
United States Board of Tax Appeals
Losses sustained in farming, when engaged in as a business, are deductible.
1Opinion of the Court
*1300OPINION.
Milliken:
Section 214 of the Revenue Act of 1921 enumerates the deductions allowed individuals in computing net income and provides in paragraph (4) for the deduction of losses sustained during the taxable year and not compensated for by insurance or otherwise if incurred in a trade or business. There is no dispute that the petitioner suffered a loss of $11,123.82 during the year 1921 in the operation of Red Hill Farm, but the controversy relates to whether the petitioner operated the farm during the year 1921 as a business for profit or merely for recreation or pleasure.
In the…
2Cases cited5 opinions
- Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- Thacher v. LoweDistrict Court, S.D. New York · 1922
- Wilson v. EisnerCourt of Appeals for the Second Circuit · 1922
- Plant v. WalshDistrict Court, D. Connecticut · 1922
3Cited by8 opinions
- Patterson v. United StatesUnited States Court of Claims · 1972
- Brueck v. CommissionerUnited States Tax Court · 1964
- Avery v. CommissionerUnited States Board of Tax Appeals · 1942
- Barbour v. CommissionerUnited States Tax Court · 1976
- Cope v. CommissionerUnited States Tax Court · 1953
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