Spanish Trail Land Co. v. Commissioner
United States Tax Court
Petitioner, a Texas corporation, upon its organization received from its incorporators conveyances of certain real estate located in Houston, Texas, in exchange for all of its capital stock. Between the dates of its incorporation and the taxable year 1944, petitioner sold or exchanged much of this real estate. All sales were made through independent real estate brokers.
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Petitioner, a Texas corporation, upon its organization received from its incorporators conveyances of certain real estate located in Houston, Texas, in exchange for all of its capital stock. Between the dates of its incorporation and the taxable year 1944, petitioner sold or exchanged much of this real estate. All sales were made through independent real estate brokers. In 1944 petitioner sold the remainder of its real estate, including 15 acres which comprised 3 separate small tracts, and returned the profit therefrom as capital gain. Held, the real estate in question was property held by…
1Opinion of the Court
OPINION.
Black, Judge.
The Commissioner has determined a deficiency in petitioner’s income tax for the year 1944 of $368.80 and a deficiency in petitioner’s declared value excess-profits tax for the same year of $1,994.41. The deficiencies are due to adjustments made to net income as reported by petitioner’s return, which were explained in the deficiency notice as follows:
(a & b) It is held that the real estate disposed of during the year 1944 was held for sale in the ordinary course of the corporation’s business." The net profit shown on your return of $24,047.71 has been increased to…
2Cited by10 opinions
- Abbott v. CommissionerUnited States Tax Court · 1957
- Dressen v. CommissionerUnited States Tax Court · 1952
- Wibbelsman v. CommissionerUnited States Tax Court · 1949
- Abbott v. CommissionerUnited States Tax Court · 1957
- Dressen v. CommissionerUnited States Tax Court · 1952
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