Legal Opinion

Townend v. Commissioner

United States Tax Court

Decided October 22, 1956No. Docket No. 51448Published

1. Petitioner and her brother and sister owned as partners certain inherited real property. Petitioner also owned real property individually. All of such properties were held primarily for rentals, but from time to time sales would be made. There were no purchases or acquisitions to replace items sold, and no general plan to liquidate either the partnership or the individual holdings.

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1. Petitioner and her brother and sister owned as partners certain inherited real property. Petitioner also owned real property individually. All of such properties were held primarily for rentals, but from time to time sales would be made. There were no purchases or acquisitions to replace items sold, and no general plan to liquidate either the partnership or the individual holdings. In 1945 and 1946 petitioner sold individually owned properties at a loss, while in 1946 the partnership sold properties at a profit. Held, the sale in 1945 was not attributable to the operation of a trade or…

1Opinion of the Court

Mae E. Townend, Petitioner, v. Commissioner of Internal Revenue, Respondent

Townend v. Commissioner

Docket No. 51448

United States Tax Court

27 T.C. 99; 1956 U.S. Tax Ct. LEXIS 64;

October 22, 1956, Filed

Decision will be entered for the respondent.

1. Petitioner and her brother and sister owned as partners certain inherited real property. Petitioner also owned real property individually. All of such properties were held primarily for rentals, but from time to time sales would be made. There were no purchases or acquisitions to replace items sold, and no general plan to liquidate either the…

2Cases cited16 opinions

  1. Neuberger v. CommissionerSupreme Court of the United States · 1940
  2. Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
  3. Guggenheim v. HelveringCourt of Appeals for the Second Circuit · 1941
  4. Sic v. CommissionerUnited States Tax Court · 1948
  5. Lazier v. United StatesCourt of Appeals for the Eighth Circuit · 1948

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