The respondent determined a deficiency in income tax against the petitioners for the taxable year 1955 in the amount of $1,148.77. The question is whether a loss sustained upon the sale of a racehorse is to be considered as a loss from the sale of a capital asset, within the meaning of section 1231 of the Internal Revenue Code of 1954, the determination of the question turning on whether the horse was held by petitioners for breeding purposes within the meaning of section...
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