Jockey Club v. Helvering

We do not think that the petitioner was a “scientific” corporation within section 231 (6) of the Act of 1926, 26 USCA § 982 (6), and section 103 (6) of the Act of 1928, 26 USCA § 2103 (6), though in a loose sense it might be possible to find a scientific aspect to some of its activities. It was in part a horse breeder, maintaining an experimental breeding station and a breeding bureau; and it is quite true that until relatively modern times such knowledge of heredity as we had was- derived from those who bred domestic animals. It would be hard to deny the name of science to their lore. But…