Jewell v. Commissioner
United States Tax Court
A breeder and seller of standard-bred trotting racehorses was attempting to build up the quality of his breeding herd. He changed from selling most of the colts foaled as weanlings to holding all of the colts until they were yearlings. Only a small percentage of colts possessed the qualities desired in a member of the breeding herd, and the rest were sold as yearlings. Eleven horses involved were sold as yearlings during the taxable years.
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A breeder and seller of standard-bred trotting racehorses was attempting to build up the quality of his breeding herd. He changed from selling most of the colts foaled as weanlings to holding all of the colts until they were yearlings. Only a small percentage of colts possessed the qualities desired in a member of the breeding herd, and the rest were sold as yearlings. Eleven horses involved were sold as yearlings during the taxable years. None of the 11 had been used for breeding or racing, and in the case of 3 of the horses the taxpayer owned only a partial interest. Held, 3 of the 11…
1Opinion of the Court
Robert B. Jewell and Margaret E. Jewell, Petitioners, v. Commissioner of Internal Revenue, Respondent
Jewell v. Commissioner
Docket No. 51132
United States Tax Court
25 T.C. 109; 1955 U.S. Tax Ct. LEXIS 68;
October 26, 1955, Filed
Decision will be entered under Rule 50.
A breeder and seller of standard-bred trotting racehorses was attempting to build up the quality of his breeding herd. He changed from selling most of the colts foaled as weanlings to holding all of the colts until they were yearlings. Only a small percentage of colts possessed the qualities desired in a member of the breeding herd,…
2Cases cited11 opinions
- McDonald v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Bradford v. CommissionerUnited States Tax Court · 1954
- Fox v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
- Fox v. CommissionerUnited States Tax Court · 1951
- McDonald v. CommissionerUnited States Tax Court · 1955
6 more not listed; retrieve them via the Exa API.