Legal Opinion

Ellsworth v. Commissioner

United States Tax Court

Decided February 15, 1962No. Docket No. 89892UnpublishedCited by 4 opinions

Petitioner, an experienced breeder of dairy cattle for many years, reentered the occupation in 1948 on his farm known as "Folly Farm." About 10 to 15 years are required to develop a breeding herd with a superior strain and of substantial commercial value. Throughout said experimental period a large number of totally or partially unproductive animals must be maintained at considerable expense.

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Petitioner, an experienced breeder of dairy cattle for many years, reentered the occupation in 1948 on his farm known as "Folly Farm." About 10 to 15 years are required to develop a breeding herd with a superior strain and of substantial commercial value. Throughout said experimental period a large number of totally or partially unproductive animals must be maintained at considerable expense. During the taxable years 1956 through 1958, inclusive, virtually all of petitioner's personal attention was devoted to his farm operations, including the supervision of 12 full time employees, planning…

1Opinion of the Court

John S. Ellsworth and Eleanor M. Ellsworth v. Commissioner.

Ellsworth v. Commissioner

Docket No. 89892.

United States Tax Court

T.C. Memo 1962-32; 1962 Tax Ct. Memo LEXIS 277; 21 T.C.M. (CCH) 145; T.C.M. (RIA) 62032;

February 15, 1962

Petitioner, an experienced breeder of dairy cattle for many years, reentered the occupation in 1948 on his farm known as "Folly Farm." About 10 to 15 years are required to develop a breeding herd with a superior strain and of substantial commercial value. Throughout said experimental period a large number of totally or partially unproductive animals must be maintained…

2Cases cited10 opinions

  1. Henry P. White and Estate of Nancy A. White, Deceased, T. Leo Sullivan, Administrator, C.T.A. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
  2. Thacher v. LoweDistrict Court, S.D. New York · 1922
  3. Morton v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  4. Wilson v. EisnerCourt of Appeals for the Second Circuit · 1922
  5. Widener v. CommissionerUnited States Board of Tax Appeals · 1927

5 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
  2. Patterson v. United StatesUnited States Court of Claims · 1972
  3. Bagley v. United StatesDistrict Court, C.D. California · 2013
  4. Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967

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