¶1dissenting: The petitioner contemplated when he went into this business that he would be able to sell some of his animals at a profit even while he was building up his herd, and it is unrealistic to regard all of his animals sold as a part of his breeding herd.
31 T.C. 752
Hancock v. Commissioner
Decided January 21, 1959
United States Tax Court · decided 1959-01-21
During 1953 petitioners sold certain cattle which had been held by them for more than 12 but less than 25 months as part of their breeding herd, but which had been culled from that herd because of… Held: at the time of their sale those cattle were held for breeding purposes within the meaning of section 117(j)(1) of the 1939 Code, thus entitling petitioners to treat the gains realized thereon as long-term capital gains.
Cited by 2 later decisions — most recently November 1966
Good law ✅— No negative treatment on recordhow we know
Decision will be entered under Rule 50 · Decided 1959-01-21
View the full empirical analysis of this case →