STEVENS v. C. I. R.

No. 17541.

388 F.2d 298 (1968)

Herbert K. STEVENS and Mrs. Herbert K. L. L. Stevens, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

January 19, 1968.


Attorney(s) appearing for the Case

William H. Beck, Lexington, Ky., for petitioners.

Issie L. Jenkins, Dept. of Justice, Washington, D. C., for respondent; Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Solomon L. Warhaftig, Issie L. Jenkins, Attys., Dept. of Justice, Washington, D. C., on brief.

Before O'SULLIVAN, PHILLIPS and CELEBREZZE, Circuit Judges.


PER CURIAM.

Taxpayer appeals from a judgment of the Tax Court of the United States denying certain deductions as ordinary and necessary business expenses under § 162 of the Internal Revenue Code of 1954. The question presented by the petition is whether the cost of maintaining and training race horses can be deducted from the gross income of the taxpayer as ordinary and necessary business expenses where the maintenance and training were provided as consideration...

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