Sonnabend v. Commissioner
United States Tax Court
Abraham M. Sonnabend purchased a farm and herd of cattle and engaged in the business of cattle breeding. Later he purchased another herd, improved the farm, and formed a partnership with his sons to continue the business. He claimed deductions attributable to this business which in each year for 5 consecutive years exceeded by more than $ 50,000 the gross income from such business.
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Abraham M. Sonnabend purchased a farm and herd of cattle and engaged in the business of cattle breeding. Later he purchased another herd, improved the farm, and formed a partnership with his sons to continue the business. He claimed deductions attributable to this business which in each year for 5 consecutive years exceeded by more than $ 50,000 the gross income from such business. Held: 1. Respondent properly applied section 270, I.R.C. 1954, limiting the deductions allowed for the fiscal year ended in 1958. 2. The notice of deficiency, mailed within 1 year after expiration of the normal…
1Opinion of the Court
Estate of Abraham M. Sonnabend, Deceased, Roger P. Sonnabend, Paul Sonnabend, Stephen Sonnabend, and Leopold Sonnabend, Executors, and Esther Sonnabend, Petitioners, v. Commissioner of Internal Revenue, Respondent
Sonnabend v. Commissioner
Docket No. 1838-63
United States Tax Court
46 T.C. 382; 1966 U.S. Tax Ct. LEXIS 86;
June 20, 1966, Filed
Decision will be entered under Rule 50.
Abraham M. Sonnabend purchased a farm and herd of cattle and engaged in the business of cattle breeding. Later he purchased another herd, improved the farm, and formed a partnership with his sons to continue the business.…
2Cases cited4 opinions
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
- Alexander v. CommissionerUnited States Tax Court · 1954
- MacMurray v. CommissionerUnited States Tax Court · 1953
- Sonnabend v. CommissionerUnited States Tax Court · 1966