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Income Tax Keyed to Lind
Engdahl v. Commissioner
Citation:
72 T.C. 659 (U.S.T.C. 1979)Facts
In 1964, Petitioners began operating a horse-breeding business. Petitioners did substantial preparatory work and sought guidance on how to grow their business. They worked 35-55 hours a week on average, building much of the ranch themselves. The couple did not use the horses or the ranch for personal pleasure but intended to make a profit to supplement their income.
Over the years, the business proved to be unprofitable and Petitioners posted a series of losses. Petitioners applied these losses to the husband’s income from his orthodontist practice. In the notice of deficiency, Respondent disallowed these losses and the claimed investment tax credits based on the conclusion that Petitioners’ horse operation was an activity not engaged in for profit.
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