Legal Opinion

Amory v. Commissioner

United States Board of Tax Appeals

Decided April 30, 1931No. Docket Nos. 42847, 44676PublishedCited by 15 opinions

Held, that petitioner's racing stable was undertaken and operated as a business and that losses sustained are deductible from income.

1Opinion of the Court

*1399OPINION.

Van Fossan :

Respondent determined deficiencies in income taxes for the years 1925, 1926, and 1927 in the respective amounts of $5,474.94, $545.36, and $22,561.33. . The basis of the deficiencies is found in respondent’s determination that the racing stable operated by petitioner was not a business enterprise operated for a profit. This is the first question for our decision. If it be decided in petitioner’s favor, the further question is the amount of petitioner’s operating loss in each year.

The evidence discloses that prior to 1924 petitioner owned no horses and had been only…

2Cited by15 opinions

  1. Matilda M. Brooks v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  2. Fisher v. CommissionerUnited States Board of Tax Appeals · 1934
  3. Curtis v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Ellsworth v. CommissionerUnited States Tax Court · 1962
  5. Kent v. CommissionerUnited States Tax Court · 1953

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