LOCKHART v. COMMISSIONER

Docket No. 89447.

43 T.C. 776 (1965)

L. M. LOCKHART, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 15, 1965.


Attorney(s) appearing for the Case

Carl F. Bauersfeld, for the petitioner.

Harold Friedman, for the respondent.


TRAIN, Judge:

The respondent determined deficiencies in petitioner's income tax for the years 1952 and 1954 in the amounts of $206,024.50 and $303,970.93, respectively.

The issues for decision are:

(1) Whether petitioner's deductions arising from the operation of a ranch in excess of petitioner's gross income from the ranch plus $50,000 per year plus specially treated deductions were properly disallowed under section 270 of the Internal Revenue...

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