George T. McLean and Amelia G. McLean v. Commissioner of Internal Revenue

Disallowing the taxpayers’ claimed deduction for a loss of $12,548.98 sustained in the operation of a horse farm in the year 1953, The Commissioner of Internal Revenue determined a tax deficiency against the taxpayers of $7,929.86. The case is before us on the taxpayers’ petition for review.

The claim for the deduction is based upon the alleged operation of the farm as a business in 1953. While the Commissioner recognized that losses incurred in the business of training, breeding and showing horses would be deductible, he determined that in 1953 the activities in question were carried on not…