Davock v. Commissioner
United States Tax Court
Petitioner acquired two tracts of land, one of which he held for more than 6 months, the other of which he held less than 6 months. He purchased one of the tracts knowing he would be forced to sell at a loss, but that the purchase of that tract was necessary in order to make a profitable sale of the other much larger tract. Petitioner took a short-term capital loss on the latter acquired land.
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Petitioner acquired two tracts of land, one of which he held for more than 6 months, the other of which he held less than 6 months. He purchased one of the tracts knowing he would be forced to sell at a loss, but that the purchase of that tract was necessary in order to make a profitable sale of the other much larger tract. Petitioner took a short-term capital loss on the latter acquired land. Respondent contends that both parcels of land were sold as a unit, an unallocated sales price being received by petitioner therefor. Respondent contends that petitioner received an amount equal to his…
1Opinion of the Court
Harlow N. Davock, Petitioner, v. Commissioner of Internal Revenue, Respondent
Davock v. Commissioner
Docket No. 36501
United States Tax Court
20 T.C. 1075; 1953 U.S. Tax Ct. LEXIS 59;
September 25, 1953, Promulgated
Decision will be entered under Rule 50.
Petitioner acquired two tracts of land, one of which he held for more than 6 months, the other of which he held less than 6 months. He purchased one of the tracts knowing he would be forced to sell at a loss, but that the purchase of that tract was necessary in order to make a profitable sale of the other much larger tract. Petitioner took a…
2Cases cited6 opinions
- C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1949
- Lakeside Irr. Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1942
- Morris Investment Corp. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1946
- Mahaffey v. HelveringCourt of Appeals for the Eighth Circuit · 1944
- Owen v. United StatesDistrict Court, D. Nebraska · 1951
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