Dunn v. Commissioner
United States Tax Court
1. Petitioner-husband engaged in harness horse racing and breeding activities. Held, on the facts, he did not carry on a trade or business or engage in an activity for profit during the taxable years at issue.
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1. Petitioner-husband engaged in harness horse racing and breeding activities. Held, on the facts, he did not carry on a trade or business or engage in an activity for profit during the taxable years at issue. Sec. 183, I.R.C. 1954. 2. All of petitioner-wife's shares in a corporation, which held a General Motors franchise, were redeemed in 1970 under an agreement which provided for a 12-year payout of the redemption price, payments being subject to certain restrictions incorporated in the agreement in order to meet the requirements imposed on the corporation by General Motors as conditions to…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in. petitioners’ Federal income tax as follows:
Year Deficiency
1970.$50,531.75
1971.21,618.10
The issues remaining for our decision are: (1) Whether petitioner Herbert Dunn was engaged in the trade or business of harness horse racing and breeding and (2) whether the redemption of petitioner Georgia Dunn’s stock in Bresee Chevrolet, Inc., constituted a complete termination of her interest in the corporation under sections 302(b)(3)1 and 302(c)(2).
GENERAL FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The…
2Cases cited25 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Clement L. Hirsch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- United States v. DavisSupreme Court of the United States · 1970
20 more not listed; retrieve them via the Exa API.
3Cited by221 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Allen v. CommissionerUnited States Tax Court · 1979
- Flowers v. CommissionerUnited States Tax Court · 1983
216 more not listed; retrieve them via the Exa API.