Legal Opinion

Fowler v. Commissioner

United States Tax Court

Decided March 22, 1962No. Docket No. 77439Published

Petitioners are the owners and operators of a racing stable, the primary purpose of which is the racing of horses at public tracks for profit. Some of the horses raced by them have been acquired by purchase and some they raised.

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Petitioners are the owners and operators of a racing stable, the primary purpose of which is the racing of horses at public tracks for profit. Some of the horses raced by them have been acquired by purchase and some they raised. Petitioners and three others, also operators of racing stables, purchased a young stallion with two purposes in mind, first, to race him in stake races for purses, and at an appropriate time thereafter to use him as a sire in their breeding operations. The horse so acquired was sold by the purchasers approximately 11 months after he had been acquired. During the time…

1Opinion of the Court

Anderson Fowler and Genevieve B. Fowler, Petitioners, v. Commissioner of Internal Revenue, Respondent

Fowler v. Commissioner

Docket No. 77439

United States Tax Court

37 T.C. 1124; 1962 U.S. Tax Ct. LEXIS 169;

March 22, 1962, Filed

Decision will be entered for the respondent.

Petitioners are the owners and operators of a racing stable, the primary purpose of which is the racing of horses at public tracks for profit. Some of the horses raced by them have been acquired by purchase and some they raised. Petitioners and three others, also operators of racing stables, purchased a young stallion with two…

2Cases cited3 opinions

  1. Jewell v. CommissionerUnited States Tax Court · 1955
  2. Fowler v. CommissionerUnited States Tax Court · 1962
  3. Estate of Collings v. United StatesDistrict Court, W.D. Kentucky · 1955

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