Stevens v. Commissioner
United States Tax Court
Petitioner entered into four joint ventures with Marion H. Woody involving the acquisition of race horses to be raced for profit. In each of such ventures, Woody paid the entire purchase price for the horse and thereafter petitioner bore the entire cost of boarding and training. The parties divided equally all racing winnings and proceeds from sale of the horses. Petitioner deducted the entire cost of maintenance and training of these four horses.
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Petitioner entered into four joint ventures with Marion H. Woody involving the acquisition of race horses to be raced for profit. In each of such ventures, Woody paid the entire purchase price for the horse and thereafter petitioner bore the entire cost of boarding and training. The parties divided equally all racing winnings and proceeds from sale of the horses. Petitioner deducted the entire cost of maintenance and training of these four horses. Held: 1. One-half of the total expenses deducted by petitioner for maintenance and training of the four horses which he owned jointly with Woody…
1Opinion of the Court
Hoyt, Judge:
Respondent determined the following deficiencies in petitioners’ j oint Federal income tax returns:
Taxable year Deficiency
1960_ $1,075.32
1961_ 1,072.54
1962_ 485.28
Total. 2, 633.14
Petitioners have previously agreed to all but one of the several adjustments set forth in the notice of deficiency. The only issues remaining for our decision are:(1) Whether expenditures made by petitioner, Herbert K. Stevens, for the training and boarding of four horses are deductible as ordinary and necessary business expenses or whether they must be capitalized as the cost of purchasing one-half…
2Cases cited1 opinion
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
3Cited by7 opinions
- Lychuk v. Comm'rUnited States Tax Court · 2001
- Herbert K. Stevens and Mrs. Herbert K. L. L. Stevens v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
- David J. Lychuk and Mary K. Lychuk v. CommissionerUnited States Tax Court · 2001
- Grant v. CommissionerUnited States Tax Court · 1980
- Huber v. CommissionerUnited States Tax Court · 1984
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