Fields v. Commissioner
United States Tax Court
Petitioners commenced a cattle-raising operation in 1973. They expended substantial funds and great effort in deveoping their land, although they incurred an uninterrupted series of losses from the farm over a number of years. Held, for the taxable years 1975 through 1977 petitioners' cattle-breeding operation was an activity engaged in for profit and therefore is not within the reach of sec. 183, I.R.C. 1954. Effect of decision limited to years at issue.
1Opinion of the Court
ALAN B. FIELDS, JR. AND JUDITH P. FIELDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Fields v. Commissioner
Docket No. 11492-79.
United States Tax Court
T.C. Memo 1981-550; 1981 Tax Ct. Memo LEXIS 190; 42 T.C.M. (CCH) 1220; T.C.M. (RIA) 81550;
September 28, 1981.
Petitioners commenced a cattle-raising operation in 1973. They expended substantial funds and great effort in deveoping their land, although they incurred an uninterrupted series of losses from the farm over a number of years. Held, for the taxable years 1975 through 1977 petitioners' cattle-breeding operation was an…
2Cases cited19 opinions
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
- 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
14 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Osteen v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 1995