Legal Opinion

Margit Sigray Bessenyey v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided June 1, 1967No. 368, Docket 30659PublishedCited by 300 opinions

1Opinion of the Court

FRIENDLY, Circuit Judge:

Mrs. Margit Sigray Bessenyey seeks review of a decision of the Tax Court, 45 T.C. 261 (1965), insofar as it denied the deduction of losses1 incurred in the tax years 1955-59 in the breeding and raising of horses.2 The facts are quite fully stated in Judge Raum’s opinion and a summary will suffice to expose the issue.

Mrs. Bessenyey, a woman in her fifties, resides in New York City. She is the daughter of a Hungarian count and his American wife and the granddaughter of Marcus Daly, the “copper king” of Montana. She was bom and raised on her father’s large Hungarian…

2Cases cited20 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Commissioner v. DubersteinSupreme Court of the United States · 1960
  3. Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  4. Corliss Lamont and Margaret I. Lamont v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
  5. Calvin E. Wright, District Director of Internal Revenue v. Richard v. Hartsell, Marjorie HartsellCourt of Appeals for the Ninth Circuit · 1962

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3Cited by300 opinions

  1. Dreicer v. CommissionerUnited States Tax Court · 1982
  2. Golanty v. CommissionerUnited States Tax Court · 1979
  3. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  4. Engdahl v. CommissionerUnited States Tax Court · 1979
  5. Brannen v. CommissionerUnited States Tax Court · 1982

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