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i RACING AND INCOME TAX 1- - - WASHINGTON, D. C, Dec. 2 Complexity of the question of whether racing is a business or a hobby for federal income tax purposes is emphasized by the statistical review of the official decisions on the subject that has just been made public by the National Thoroughbred Foundation. The review states: "The National Thoroughbred Foundation has completed a statistical summary of the official decisions of the commissioner of internal revenue and the board of tax appeals and the federal courts on the question of whether the breeding, racing and showing of blooded horses is a business or a hobby for federal income tax purposes. This question has been at issue since the first income tax act was enacted in 1913. "There now exist seventeen decisions dealing directly and comprehensively with the subject, including eleven decisions by the board of tax appeals, one decision by the commissioner of internal revenue made before the tax board was founded and five decisions by the federal courts. "Of the eleven decisions of the board of tax appeals, six are favorable to the proposition and five unfavorable. The decision of the commissioner of internal revenue before the board was created is unfavorable. "Of the five decisions of the federal courts, four are favorable and one unfavorable, although the latter deals with the breeding and showing of horses. The decisions which cover the question of the breeding and racing of horses all hold it to be a business. "All of the seventeen decisions are to be found in the Foundations book, Racing and the Income Tax, which has been published for the information and guidance of breeders and owners of racing establishments who are perplexed by the question. Inquiries concerning this book should be addressed to the National Thoroughbred Foundation, Box 578, Washington, D. C."
