Pickering v. Commissioner
United States Tax Court
Petitioners purchased farmland in 1951, but did not work or live on the land until 1969. From 1969 to, and including, the taxable years involved, petitioners sharecropped their tobacco allotment, and raised some hay for the feeding of their small number of horses and beef cattle. However, the facts show that petitioners did not approach the operation of the farm during the taxable years involved with the intent of making a profit.
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Petitioners purchased farmland in 1951, but did not work or live on the land until 1969. From 1969 to, and including, the taxable years involved, petitioners sharecropped their tobacco allotment, and raised some hay for the feeding of their small number of horses and beef cattle. However, the facts show that petitioners did not approach the operation of the farm during the taxable years involved with the intent of making a profit. Held, petitioners are not entitled to deduct farm expenses in excess of those allowed by section 183, I.R.C. 1954; held further, petitioners are not allowed an…
1Opinion of the Court
NORMAN R. and CAROLINE W. PICKERING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
Pickering v. Commissioner
Docket No. 9746-77.
United States Tax Court
T.C. Memo 1979-243; 1979 Tax Ct. Memo LEXIS 286; 38 T.C.M. (CCH) 964; T.C.M. (RIA) 79243;
June 25, 1979, Filed
Petitioners purchased farmland in 1951, but did not work or live on the land until 1969. From 1969 to, and including, the taxable years involved, petitioners sharecropped their tobacco allotment, and raised some hay for the feeding of their small number of horses and beef cattle. However, the facts show that petitioners did…
2Cases cited15 opinions
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Dunn v. CommissionerUnited States Tax Court · 1978
- Sharon v. CommissionerUnited States Tax Court · 1976
- Benz v. CommissionerUnited States Tax Court · 1974
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
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