Taylor S. Hardin and Katherine B. Hardin v. Commissioner of Internal Revenue

Fourth Circuit

Taylor S. Hardin and Katherine B. Hardin v. Commissioner of Internal Revenue

507 F.2d 903, 35 A.F.T.R.2d (RIA) 460, 1974 U.S. App. LEXIS 5517

Court of Appeals for the Fourth Circuit·Decided December 23, 1974·No. 74-1438·Published

Opinion

PER CURIAM:

We agree with the Tax Court that when the taxpayers owned the race horse for only twenty-seven days prior to the end of the calendar year, they were entitled to claim depreciation for only the period of ownership and not for a full year, notwithstanding that by the rule of the sport a thoroughbred race horse is deemed to be one year older on January 1 of each year. We affirm on the memorandum opinion of the Tax Court. Taylor S. Hardin, 32 T.C.M. 892 (1973).

Affirmed.

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PER CURIAM:

We agree with the Tax Court that when the taxpayers owned the race horse for only twenty-seven days prior to the end of the calendar year, they were entitled to claim depreciation for only the period of ownership and not for a full year, notwithstanding that by the rule of the sport a thoroughbred race horse is deemed to be one year older on January 1 of each year. We affirm on the memorandum opinion of the Tax Court. Taylor S. Hardin, 32 T.C.M. 892 (1973).

Affirmed.

Taylor S. Hardin and Katherine B. Hardin v. Commissioner of Internal Revenue, 507 F.2d 903, 35 A.F.T.R.2d (RIA) 460, 1974 U.S. App. LEXIS 5517 (4th Cir. 1974).

Pincite

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Opinion

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