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Churchill Downs, Inc. v. Commissioner

United States Court of Appeals for the Sixth Circuit
307 F.3d 810 (2002)


Churchill Downs, Inc. (Churchill) (plaintiff) operated a race track in Louisville, Kentucky. Churchill held national horse races, including the Kentucky Derby, at the race track. Churchill generated income from selling admissions and wagers at the races. In connection with major races, Churchill hosted invitation-only cocktail parties, celebrity galas, and other events to promote attendance at the races. There were no horses at these pre-race events or any information or opportunities related to placing wagers. Churchill deducted the full cost of these promotional events on its federal income-tax return as ordinary and necessary business expenses. The federal tax commissioner (commissioner) (defendant) determined that Churchill was entitled to deduct only 50 percent of these expenses. Churchill petitioned the United States Tax Court for a redetermination. The tax court entered judgment in favor of the commissioner. Churchill appealed to the United States Court of Appeals for the Sixth Circuit.

Rule of Law


Holding and Reasoning (Siler, J.)

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