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Gamble v. Commissioner
United States Tax Court
68 T.C. 800 (1977)
Launce Gamble (plaintiff) was involved in thoroughbred horse racing and acquired 13 horses between 1964 and 1974. In 1969 Gamble purchased a horse called Champagne Woman for $60,000. Champagne Woman was carrying a foal fathered by a horse known for siring champion racehorses. Gamble purchased an insurance policy that had $20,000 of coverage for the expected foal. Two years later, Gamble sold the foal for $125,000. When determining his profit from the sale for income-tax purposes, Gamble subtracted selling expenses and $30,000 as the foal’s cost basis, determined based on the father’s stud fee, averaging approximately $28,000, at the time he sired the foal. The Commissioner of Internal Revenue (the Commissioner) (defendant) held that the foal’s cost basis was zero and that Gamble had erroneously allocated half of Champagne Woman’s purchase price to the foal. Gamble petitioned the United States Tax Court for a redetermination.
Rule of Law
Holding and Reasoning (Raum, J.)
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