Taylor S. Hardin and Katherine B. Hardin v. Commissioner of Internal Revenue

PER CURIAM: We agree with the Tax Court that when the taxpayers owned the race horse for only twenty-seven days prior to the end of the calendar year, they were entitled to claim depreciation for only the period of ownership and not for a full year, notwithstanding that by the rule of the sport a thoroughbred race horse is deemed to be one year older on January 1 of each year. We affirm on the memorandum opinion of the Tax Court. Taylor S. Hardin, 32 T.C.M. 892 (1973). Affirmed.