United States Tax Court October 26, 1955, Docket No. 51132 (Jewell v. Commissioner)

lead-opinion

OPINION.

Bruce, Judge:

The question presented is whether horses foaled on Jewell’s farm and sold as yearlings during the taxable years involved were held for breeding purposes and were, therefore, “property used in the trade or business” within the purview of section 117 (j) (1), Internal Revenue Code of 1939.