United States Court of Appeals for the Seventh Circuit
700 F.2d 402 (1983)
Melvin Nickerson (plaintiff) worked as a self-employed advertising professional and was looking for a new career. Having worked evenings and weekends on his father’s farm as a teenager, Nickerson decided that starting a dairy-farm business would be a profitable new career. After several years of searching for a property, Nickerson acquired an abandoned dairy farm that had been out of business for eight years. Nickerson visited the farm on weekends during growing season and twice per month for the rest of the year. Farming the land in its current condition was impossible, and Nickerson did not acquire any livestock or equipment. Whenever Nickerson visited the property, he worked on gradually renovating the farmhouse, hay barn, and equipment shed. Nickerson expected that generating a profit from the farm would take 10 years. Nickerson leased the property to a farmer, who, in addition to paying rent, aided Nickerson by cultivating the land to prepare it for farming. Nickerson deducted the farm-restoration costs as business expenses on his federal tax return. The federal tax commissioner (commissioner) (defendant) determined that Nickerson’s expenses were not tax deductible, finding that profit was not Nickerson’s primary motivation in operating the farm. Nickerson petitioned the United States Tax Court for a redetermination. The tax court ruled in favor of the commissioner, and Nickerson appealed to the United States Court of Appeals for the Seventh Circuit.
Rule of Law
Holding and Reasoning (Pell, J.)
What to do next…
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 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
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. Read more about Quimbee.
Here's why 221,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 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.