Rickard v. Commissioner
United States Tax Court
Petitioners, members of the Colville Confederated Tribes, operate a cattle farm on land held in Indian trust status by the United States pursuant to special Colville Reservation allotment acts and subject to the General Allotment Act of 1887. Held, as petitioners' farm income is exempt from tax by virtue of Squire v. Capoeman, 351 U.S. 1 (1956), petitioners are denied their farming expense deductions.
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Petitioners, members of the Colville Confederated Tribes, operate a cattle farm on land held in Indian trust status by the United States pursuant to special Colville Reservation allotment acts and subject to the General Allotment Act of 1887. Held, as petitioners' farm income is exempt from tax by virtue of Squire v. Capoeman, 351 U.S. 1 (1956), petitioners are denied their farming expense deductions. Sec. 265(1), I.R.C. 1954; sec. 1.265-1(b)(1), Income Tax Regs.; Manocchio v. Commissioner, 78 T.C. 989, 997 (1982), affd. 710 F.2d 1400 (9th Cir. 1983), followed. Held, further, because…
1Opinion of the Court
Donald A. Rickard and Estate of Eva C. Rickard, Deceased, Petitioners v. Commissioner of Internal Revenue, Respondent
Rickard v. Commissioner
Docket No. 3900-83
United States Tax Court
88 T.C. 188; 1987 U.S. Tax Ct. LEXIS 12; 88 T.C. No. 12;
January 21, 1987. January 21, 1987, Filed
Decision will be entered for the respondent.
Petitioners, members of the Colville Confederated Tribes, operate a cattle farm on land held in Indian trust status by the United States pursuant to special Colville Reservation allotment acts and subject to the General Allotment Act of 1887. Held, as petitioners' farm income…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- National Railroad Passenger Corporation v. National Assn. of Railroad PassengersSupreme Court of the United States · 1974
- Squire v. CapoemanSupreme Court of the United States · 1956
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