Plunkett v. Commissioner
United States Tax Court
T.C. Memo. 1984-170 (1984)
- Written by Kelsey Libby, JD
Facts
H. Connely Plunkett (plaintiff) was a professional architectural engineer and participated in mud racing and truck pulling in his spare time. Plunkett began mud racing in 1975 with no prior experience and participated in over 50 competitions through 1978. The potential for profit was low due to the elimination structure and likelihood of damage to the vehicles. In 1977, Plunkett became more interested in truck pulling. Truck pulling was increasing in popularity, and events drew up to 15,000 paying spectators, which resulted in larger winnings. A truck-pulling participant could win up to $2,000 in a weekend. Plunkett eventually became the 35th-ranked truck puller in the nation and treated the endeavor in a fashion similar to his construction business. Plunkett spent about 500 hours per year on mud racing and truck pulling. Plunkett deducted his full expenses incurred mud racing and truck pulling for the tax years 1976 through 1978. The commissioner of internal revenue (defendant) disallowed the deductions on the grounds that the activities were not engaged in for profit. Plunkett sought review in the tax court.
Rule of Law
Issue
Holding and Reasoning (Goffe, J.)
What to do next…
Here's why 832,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,500 briefs, keyed to 994 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.
