Estate of Webb v. Commissioner
United States Tax Court
During the years 1946, 1947, and 1948, Webb had no regular employment but engaged in numerous real estate transactions. He held stock in several real estate corporations and was president of two of them. Frequently, he purchased real estate with funds furnished by others and received a share of any profit when the real estate was sold.
Read the full summary
During the years 1946, 1947, and 1948, Webb had no regular employment but engaged in numerous real estate transactions. He held stock in several real estate corporations and was president of two of them. Frequently, he purchased real estate with funds furnished by others and received a share of any profit when the real estate was sold. Held: (1) Webb was in the business of buying and selling real estate and gains from the sale of real estate during the years 1946 to 1948, inclusive, were taxable as ordinary income. (2) Webb omitted from his 1946 income tax return income in an amount properly…
1Opinion of the Court
Bruce, Judge:
^Respondent determined deficiencies in income tax of petitioners as follows:
Year Docket No. Deficiency
1946- 54756 $2, 725. 61
1947- 54756 1, 560.15
1948- 54755 582. 82
1949- 54755 1, 345.28
The cases were consolidated for hearing. Subsequent to the filing of the petitions, Frankie L. Webb remarried and her present name, Frankie L. Sebat, has been substituted in the captions of these cases.
There is no issue in this proceeding in regard to the statute of limitations as to any of the years 1947, 1948, and 1949. The petitioners concede that the period of limitation upon the assessment…
2Cases cited7 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Magruder v. SuppleeSupreme Court of the United States · 1942
- Phillips v. Comissioner of Internal RevenueUnited States Tax Court · 1955
- Clark v. CommissionerUnited States Tax Court · 1957
2 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Adam v. CommissionerUnited States Tax Court · 1973
- Barnsley v. CommissionerUnited States Tax Court · 1959
- Harris v. CommissionerUnited States Tax Court · 1966
- Hicks v. CommissionerUnited States Tax Court · 1978
- Stoller v. CommissionerUnited States Tax Court · 1983
17 more not listed; retrieve them via the Exa API.