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

Court of Appeals for the Third Circuit·Decided January 25, 1966·No. 15419·Published

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.

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).

Pincite

354 F.2d 659 (Alfred M. Cox and Helen B. Cox v. Commissioner of Internal Revenue) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.