Heebner v. Commissioner
United States Tax Court
Sec. 117(a)(1)(A), I.R.C. 1939. -- Petitioner had been engaged in the building and construction business for many years. Incidentally, he had been engaged in "package building," which meant that he would procure a satisfactory site, construct a building according to specification, procure financing, and turn over a completed project. In 1951 he began to plan the construction and leasing of a warehouse for Nash-Kelvinator.
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Sec. 117(a)(1)(A), I.R.C. 1939. -- Petitioner had been engaged in the building and construction business for many years. Incidentally, he had been engaged in "package building," which meant that he would procure a satisfactory site, construct a building according to specification, procure financing, and turn over a completed project. In 1951 he began to plan the construction and leasing of a warehouse for Nash-Kelvinator. The building was to be purchased by Prudential Insurance Co. It was constructed by taxpayer through a controlled corporation and was purchased by Prudential as planned.…
1Opinion of the Court
George K. Heebner, Jr., and Ruth S. Heebner, Petitioners, v. Commissioner of Internal Revenue, Respondent
Heebner v. Commissioner
Docket No. 64882
United States Tax Court
32 T.C. 1162; 1959 U.S. Tax Ct. LEXIS 94;
September 10, 1959, Filed
Decision will be entered under Rule 50.
Sec. 117(a)(1)(A), I.R.C. 1939. -- Petitioner had been engaged in the building and construction business for many years. Incidentally, he had been engaged in "package building," which meant that he would procure a satisfactory site, construct a building according to specification, procure financing, and turn over a completed…
2Cases cited4 opinions
- Williamson v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Williamson v. CommissionerUnited States Tax Court · 1952
- Heebner v. CommissionerUnited States Tax Court · 1959
- Estate of Hyman Kleinman, Deceased, Morris A. Kleinman and Reuben Kleinman, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957