Anthony IMBESI and Hazel Imbesi, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Third Circuit.https://leagle.com/images/logo.png
Argued November 5, 1965.
Decided June 14, 1966.
Attorney(s) appearing for the Case
Herman H. Krekstein, Philadelphia, Pa. (Merle A. Wolfson, Krekstein, Wolfson & Krekstein, Philadelphia, Pa., on the brief), for petitioners.
Edward I. Heilbronner, Dept. of Justice, Tax Div., Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Meyer Rothwacks, David O. Walter, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.
Before STALEY and FREEDMAN, Circuit Judges, and COHEN, District Judge.
United States Court of Appeals Third Circuit.
FREEDMAN, Circuit Judge.
The taxpayer1 challenges the decision of the Tax Court sustaining the Commissioner's determination of income tax deficiencies totalling $177,452.44 which resulted from the disallowance of losses incurred in the years 1955 through 1959 in the breeding, training and exhibition of English Setter dogs and the breeding, training and racing of horses. The Tax Court in effect held that these activities of the taxpayer...
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