BESSENYEY v. C. I. R.

No. 368, Docket 30659.

379 F.2d 252 (1967)

Margit Sigray BESSENYEY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided June 1, 1967.


Attorney(s) appearing for the Case

Orrin G. Judd, New York City (Goldstein, Judd & Gurfein, New York City, Saul D. Kronovet, Earle K. Moore and Ronald Dreier, New York City, of counsel), for petitioner.

Stuart A. Smith, Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and David O. Walter, Attys., Dept. of Justice, Washington, D. C.), for respondent.

Before WATERMAN, FRIENDLY and ANDERSON, Circuit Judges.


FRIENDLY, Circuit Judge:

Mrs. Margit Sigray Bessenyey seeks review of a decision of the Tax Court, 45 T.C. 261 (1965), insofar as it denied the deduction of losses1 incurred in the tax years 1955-59 in the breeding and raising of horses.2 The facts are quite fully stated in Judge Raum's opinion and a summary will suffice to expose the issue.

Mrs. Bessenyey, a woman in...

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