Sevier Terrace Realty Company v. Commissioner of Internal Revenue

This ease involved questions concerning the taxpayer’s basis of 303 acres of land known as Mount Ida Farm and located partly within and partly without the corporate limits of Kingsport, Tennessee. A further issue was presented as to whether the taxpayer in computing its income tax may deduct, as an ordinary and necessary business expense, the fair market value of 12 lots transferred to a social and recreation center to be used only by owners or residents in the taxpayer’s subdivision rather than handling it as a capital expenditure allocable to the basis of its unsold lots.

The parties agreed…