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GJESTEBY v. COMMISSIONER

Docket No. 25340-85.

54 T.C.M. 1364 (1987)

T.C. Memo. 1987-617

Arne K. Gjesteby and Martha K. Gjesteby v. Commissioner.

United States Tax Court.

Filed December 21, 1987.

Attorney(s) appearing for the Case

Albert C. Barclay, Jr., 229 Nassau St., Princeton, N.J., for the petitioners. Charles W. Maurer, for the respondent.

Memorandum Findings of Fact and Opinion

RAUM, Judge:

The Commissioner determined a deficiency in petitioners' 1982 income tax in the amount of $15,500 and an addition to tax under section 6661, IRC 1954, in the amount of $1,550. The primary issue before us is the allowability of deductions taken by petitioners on Schedule F as farm expenses in connection with a cattle breeding investment. The Commissioner challenges the deductions on three grounds: first...

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