Legal Opinion
Estate of Elizabeth L. Power v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided June 21, 1984No. 83-1911PublishedCited by 18 opinions
1Opinion of the Court
BOWNES, Circuit Judge.
At all times relevant to this case, Elizabeth L. Power was a taxpayer residing in Middlesex County, Massachusetts, who used a fiscal year ending June 30 for federal income tax purposes. The Commissioner of Internal Revenue determined deficiencies in her reported income taxes for fiscal years 1972, 1973, 1974 and 1977 totalling $66,797.20. Mrs. Power petitioned the Tax Court for a redetermination. • The sole issue before the Tax Court was whether Mrs. Power’s horse breeding activity was “engaged in for profit” within the meaning of I.R.C. § 183 so that losses in…
2Cases cited5 opinions
- Golanty v. CommissionerUnited States Tax Court · 1979
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Harrah's Club v. United StatesUnited States Court of Claims · 1981
- Maurice C. Dreicer v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1981
- Bessenyey v. CommissionerUnited States Tax Court · 1965
3Cited by18 opinions
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Thomas C. Burger and Marian E. Burger v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
- The Brook, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
- Charla Gates Cannon v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- Filios v. CommissionerCourt of Appeals for the First Circuit · 2000
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