Legal Opinion

Hurd v. Commissioner

United States Tax Court

Decided March 22, 1978No. Docket No. 7481-74Unpublished

(1) Ps, well known professional artists, sustained substantial losses from the operation of their cattle ranch. Held, the ranch operation was not conducted to make a profit; therefore, losses sustained are not deductible. (2) Ps claimed depreciation deductions based on the entire cost of their guest facilities and a room known as the Gallery.

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(1) Ps, well known professional artists, sustained substantial losses from the operation of their cattle ranch. Held, the ranch operation was not conducted to make a profit; therefore, losses sustained are not deductible. (2) Ps claimed depreciation deductions based on the entire cost of their guest facilities and a room known as the Gallery. The Commissioner attributed 33-1/3 percent of the use of the guest facilities and 50 percent of the use of the Gallery to Ps' art business and disallowed part of the deductions claimed. Held, the Commissioner's determination is sustained. (3) Held,…

1Opinion of the Court

PETER HURD and HENRIETTE W. HURD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hurd v. Commissioner

Docket No. 7481-74.

United States Tax Court

T.C. Memo 1978-113; 1978 Tax Ct. Memo LEXIS 401; 37 T.C.M. (CCH) 499; T.C.M. (RIA) 780113;

March 22, 1978, Filed(1) Ps, well known professional artists, sustained substantial losses from the operation of their cattle ranch. Held, the ranch operation was not conducted to make a profit; therefore, losses sustained are not deductible.(2) Ps claimed depreciation deductions based on the entire cost of their guest facilities and a room known as…

2Cases cited29 opinions

  1. Jasionowski v. CommissionerUnited States Tax Court · 1976
  2. Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
  3. Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  4. Shiosaki v. CommissionerUnited States Tax Court · 1974
  5. Benz v. CommissionerUnited States Tax Court · 1974

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