Ellis v. Commissioner
United States Tax Court
Petitioners entered into an agreement to sell fill dirt from their land. Although the agreement designated the areas from which the dirt was to be removed, the buyer of the dirt was not obligated to remove all of the dirt situated therein. Held, petitioner's profit from the sale of fill dirt is taxable as ordinary income.
1Opinion of the Court
Richard L. Ellis and Edna May Ellis, Petitioners v. Commissioner of Internal Revenue, Respondent
Ellis v. Commissioner
Docket No. 1184-69
United States Tax Court
56 T.C. 1079; 1971 U.S. Tax Ct. LEXIS 80;
August 12, 1971, Filed
Decision will be entered for the respondent.
Petitioners entered into an agreement to sell fill dirt from their land. Although the agreement designated the areas from which the dirt was to be removed, the buyer of the dirt was not obligated to remove all of the dirt situated therein. Held, petitioner's profit from the sale of fill dirt is taxable as ordinary income.
Theodore A.…
2Cases cited1 opinion
- Ellis v. CommissionerUnited States Tax Court · 1971