1938 BTA LEXIS 735 | B.T.A. | 1938
Lead Opinion
The Commissioner has disallowed the losses on the stock farm on the ground that the farm was operated by the petitioner as a hobby rather than as a business for profit. He relies almost entirely upon the fact that the operation of the business has resulted in a long and uninterrupted series of losses. The evidence as a whole, however, preponderates in favor of the petitioner. This small farm was operated on a relatively modest scale. The total investment of the two partners was originally about $40,000. Only about ten or twelve horses were owned at a time. The petitioner did not live at the farm at any time. The place where he spent his summers was about thirty
Decision will be entered under Rule 50.