Bessenyey v. Commissioner

45 T.C. 261 (1965)

From our private database of 46,100+ case briefs, written and edited by humans—never with AI.

Bessenyey v. Commissioner

United States Tax Court
45 T.C. 261 (1965)

Facts

Margit Bessenyey (plaintiff) was a wealthy woman of Hungarian descent who had raised Hungarian Half-bred horses on her father’s estate in Hungary before moving to the United States in 1946. Following World War II, the United States Army brought 37 Hungarian horses to the United States, and Bessenyey purchased nine of the horses at a 1948 army sale. Bessenyey eventually began breeding the horses to continue their bloodlines and establish the Hungarian Half-bred as a recognized horse breed in the United States. Bessenyey conducted her horse-breeding operations on farms in Montana and Maryland. Bessenyey was not very concerned with the financial and business aspects of the horse-breeding operations, including the operations’ profitability, but she enjoyed horse-breeding and experienced personal satisfaction from the operations. Between 1955 and 1959, Bessenyey sustained substantial losses from the horse-breeding operations. Bessenyey deducted the losses on her income-tax returns, but the Commissioner of Internal Revenue (the commissioner) (defendant) determined that Bessenyey had improperly deducted the losses and assessed a deficiency. The commissioner asserted that because Bessenyey had not engaged in the horse-breeding operations for the purpose of making a profit, the losses associated with those operations were not deductible. Bessenyey challenged the commissioner’s determination in the United States Tax Court.

Rule of Law

Issue

Holding and Reasoning (Raum, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 748,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 748,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,100 briefs, keyed to 987 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 748,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,100 briefs - keyed to 987 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership