Alfred M. Cox and Helen B. Cox v. Commissioner of Internal Revenue

Third Circuit

Alfred M. Cox and Helen B. Cox v. Commissioner of Internal Revenue

354 F.2d 659, 17 A.F.T.R.2d (RIA) 228

CourtCourt of Appeals for the Third Circuit

DecidedJanuary 25, 1966

Docket15419

StatusPublished

This text of 354 F.2d 659 (Alfred M. Cox and Helen B. Cox v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Alfred M. Cox and Helen B. Cox v. Commissioner of Internal Revenue, 354 F.2d 659, 17 A.F.T.R.2d (RIA) 228 (3d Cir. 1966).

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Opinion

PER CURIAM.

The sole issue remaining in this tax case is whether in the years 1958 and 1959 taxpayer’s contention that he was engaged in the business of farming is correct.

The Tax Court, on substantial evidence in the whole case, found as a fact that in the years 1958 and 1959, taxpayer did not operate his farm on a commercial basis for profit. Consequently the expenses and losses sustained by his farm during that period were held not deductible under Section 165 of the Internal Revenue Code of 1954.

The decision of the Tax Court will be affirmed.

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PER CURIAM.

The sole issue remaining in this tax case is whether in the years 1958 and 1959 taxpayer’s contention that he was engaged in the business of farming is correct.

The Tax Court, on substantial evidence in the whole case, found as a fact that in the years 1958 and 1959, taxpayer did not operate his farm on a commercial basis for profit. Consequently the expenses and losses sustained by his farm during that period were held not deductible under Section 165 of the Internal Revenue Code of 1954.

The decision of the Tax Court will be affirmed.

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Bluebook (online)

354 F.2d 659, 17 A.F.T.R.2d (RIA) 228, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alfred-m-cox-and-helen-b-cox-v-commissioner-of-internal-revenue-ca3-1966.