Dunn v. Commissioner
United States Tax Court
1. Petitioner-husband engaged in harness horse racing and breeding activities. Held, on the facts, he did not carry on a trade or business or engage in an activity for profit during the taxable years at issue.
Read the full summary
1. Petitioner-husband engaged in harness horse racing and breeding activities. Held, on the facts, he did not carry on a trade or business or engage in an activity for profit during the taxable years at issue. Sec. 183, I.R.C. 1954. 2. All of petitioner-wife's shares in a corporation, which held a General Motors franchise, were redeemed in 1970 under an agreement which provided for a 12-year payout of the redemption price, payments being subject to certain restrictions incorporated in the agreement in order to meet the requirements imposed on the corporation by General Motors as conditions to…
1Opinion of the Court
Herbert A. Dunn and Georgia E. Dunn, Petitioners v. Commissioner of Internal Revenue, Respondent
Dunn v. Commissioner
Docket No. 114-76
United States Tax Court
70 T.C. 715; 1978 U.S. Tax Ct. LEXIS 72;
August 21, 1978, Filed
Decision will be entered under Rule 155.
1. Petitioner-husband engaged in harness horse racing and breeding activities. Held, on the facts, he did not carry on a trade or business or engage in an activity for profit during the taxable years at issue. Sec. 183, I.R.C. 1954.
2. All of petitioner-wife's shares in a corporation, which held a General Motors franchise, were redeemed in…
2Cases cited26 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Dunn v. CommissionerUnited States Tax Court · 1978
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
21 more not listed; retrieve them via the Exa API.