Hambleton v. Commissioner
United States Tax Court
Held: Petitioners' operation of a farm was not an activity engaged in for profit. Held further: The farming operation together with the holding of the farmland for its appreciation in value did not constitute a single activity engaged in for profit within the meaning of section 1.183-1(d), Income Tax Regs.Held further: The disallowed expenses are not deductible under section 212(2) as ordinary and necessary expenses incurred with respect to property held for investment.
1Opinion of the Court
GEORGE B. E. HAMBLETON AND JANET F. HAMBLETON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hambleton v. Commissioner
Docket No. 8467-77.
United States Tax Court
T.C. Memo 1982-234; 1982 Tax Ct. Memo LEXIS 504; 43 T.C.M. (CCH) 1257; T.C.M. (RIA) 82234;
May 3, 1982.
Held: Petitioners' operation of a farm was not an activity engaged in for profit. Held further: The farming operation together with the holding of the farmland for its appreciation in value did not constitute a single activity engaged in for profit within the meaning of section 1.183-1(d), Income Tax Regs.Held further: The…
2Cases cited12 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Allen v. CommissionerUnited States Tax Court · 1979
- Dunn v. CommissionerUnited States Tax Court · 1978
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