# Field v. Commissioner

> United States Board of Tax Appeals · May 18, 1932 · 26 B.T.A. 116

URL: https://www.frixlaw.com/law-library/cases/8308053

## Case

- **Full name:** Marshall Field v. Commissioner of Internal Revenue
- **Court:** United States Board of Tax Appeals
- **Decided:** May 18, 1932
- **Citations:** 26 B.T.A. 116
- **Precedential status:** Published
- **Opinion:** Dissent by Sternhagen
- **Judges:** Aeundell, Agree, Love, Smith, Sternhagen
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/8308053

## Opinion text

SteRNHageN,
dissenting: In my opinion, the evidence is not suf- • ficient to establish that the petitioner’s place on Long Island or his racing and breeding of horses was a trade or business. Furthermore, the artificial accounting by which petitioner’s consumption of his own produce is made to appear like a sale and purchase should have no legal weight, even although it may afford useful or interesting statistics, as many household accounts do. Cf. Louise Cheney, 22 B. T. A. 672.
AeuNdell and MtjRdock agree with this dissent.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/8308053. Public record. Not legal advice.