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Hardin v. Commissioner of Internal Revenue

United States Court of Appeals, Fourth Circuit
Dec 23, 1974
507 F.2d 903 (4th Cir. 1974)

Opinion

No. 74-1438.

Argued December 4, 1974.

Decided December 23, 1974.

Fred R. Tansill, Washington, D.C. (Paul S. Richter and Bird Tansill, Washington, D.C., on brief), for appellants.

George G. Wolf, Atty., Tax Div., U.S. Dept. of Justice (Scott P. Crampton, Asst. Atty. Gen., Ernest J. Brown and Gary R. Allen, Attys., Tax Div., U.S. Dept. of Justice, on brief), for appellee.

Appeal from the United States Tax Court.

Before WINTER, CRAVEN and RUSSELL, Circuit Judges.


We agree with the Tax Court that when the taxpayers owned the race horse for only twenty-seven days prior to the end of the calendar year, they were entitled to claim depreciation for only the period of ownership and not for a full year, notwithstanding that by the rule of the sport a thoroughbred race horse is deemed to be one year older on January 1 of each year. We affirm on the memorandum opinion of the Tax Court. Taylor S. Hardin, 32 T.C.M. 892 (1973).

Affirmed.


Summaries of

Hardin v. Commissioner of Internal Revenue

United States Court of Appeals, Fourth Circuit
Dec 23, 1974
507 F.2d 903 (4th Cir. 1974)
Case details for

Hardin v. Commissioner of Internal Revenue

Case Details

Full title:TAYLOR S. HARDIN AND KATHERINE B. HARDIN, APPELLANTS v. COMMISSIONER OF…

Court:United States Court of Appeals, Fourth Circuit

Date published: Dec 23, 1974

Citations

507 F.2d 903 (4th Cir. 1974)