Legal Opinion

Bolt v. Commissioner

United States Tax Court

Decided September 30, 1968No. Docket Nos. 3863-67, 5261-67PublishedCited by 21 opinions

Held, petitioner's activities in connection with automobile racing, under the facts in this case, constitute a trade or business and therefore the expenses of these activities are deductible.

1Opinion of the Court

Scott, Judge:

Respondent determined deficiencies in petitioner’s income tax for the calendar years 1964 and 1965 in the respective amounts of $1,069.00 and $717.75. One of the issues raised by the pleadings has 'been conceded by petitioner leaving for our decision the question of whether petitioner is entitled to deduct as ordinary and necessary expenses of carrying on a trade or business amounts which he expended in each of the years 1964 and 1965 in connection with automobile-racing activities.

FINDINGS OP FACT

Some of the facts have been stipulated and are found accordingly.

Petitioner resided…

2Cases cited4 opinions

  1. Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
  2. Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  3. Corliss Lamont and Margaret I. Lamont v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
  4. Osborn v. CommissionerUnited States Tax Court · 1944

3Cited by21 opinions

  1. Sutton v. CommissionerUnited States Tax Court · 1985
  2. Gentile v. CommissionerUnited States Tax Court · 1975
  3. United States v. Martin Wright GordonCourt of Appeals for the Fifth Circuit · 1969
  4. Hastings v. Comm'rUnited States Tax Court · 2009
  5. Free-Pacheco v. United StatesUnited States Court of Federal Claims · 2014

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