Van Raden v. Commissioner
United States Tax Court
Petitioners, cash basis taxpayers, invested as limited partners in a cash basis partnership cattle-feeding operation in mid-December 1972 whereupon the partnership in the last few days of the 1972 taxable year purchased a 1-year supply of feed and some cattle.
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Petitioners, cash basis taxpayers, invested as limited partners in a cash basis partnership cattle-feeding operation in mid-December 1972 whereupon the partnership in the last few days of the 1972 taxable year purchased a 1-year supply of feed and some cattle. The Commissioner disallowed the deduction for feed expenses for the reasons that there was no business purpose for the purchase at that time and because the income of the partnership was distorted, relying upon sec. 446(b), I.R.C. 1954. Held, petitioners proved an adequate business purpose in this case and no material distortion of…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in Federal income tax of petitioners as follows:
Docket No. Taxable year Amount
1336-76 1972 $97,763.00
1407-76 1972 108,775.80
Upon the joint motion of the parties, these cases were consolidated for purposes of trial, briefs, and opinion.
Due to concessions, the only issue remaining for our decision is: Whether Western Trio-VR, a limited partnership, of which petitioners were the limited partners, is entitled to deduct in the year of purchase and payment the cost of a 1-year supply of feed, purchased for its cattle-feeding operations, which…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Helvering v. WinmillSupreme Court of the United States · 1938
- United States v. CattoSupreme Court of the United States · 1966
- Sandor v. CommissionerUnited States Tax Court · 1974
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3Cited by67 opinions
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- Lemmen v. CommissionerUnited States Tax Court · 1981
- Hager v. CommissionerUnited States Tax Court · 1981
- Seligman v. CommissionerUnited States Tax Court · 1985
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