EDGE v. COMMISSIONER

Docket No. 5506-71.

32 T.C.M. 1291 (1973)

T.C. Memo. 1973-274

Walter E. Edge, Jr. v. Commissioner.

United States Tax Court.

Filed December 12, 1973.


Attorney(s) appearing for the Case

Paul H. Briger, 140 Broadway, New York, N.Y., for the petitioner. Fred L. Baker, for the respondent.


Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent has determined deficiencies in income tax to be due from petitioner for the taxable years 1966, 1967, and 1968, in the amounts of $31,504.60, $20,656.77, and $11,971.16, respectively. The sole question for decision is whether petitioner's operation of a beef cattle farm was a trade or business so as to entitle him to deduct the losses resulting therefrom during the taxable years 1966, 1967...

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