Adam v. Commissioner
United States Tax Court
The petitioner, who was a successful accountant and devoted full time to the practice of that profession, purchased 11 and sold 9 parcels of undeveloped land in 4 years. He acquired such properties to hold and to sell later when he could realize a satisfactory profit. Held, under sec. 1221(1), I.R.C. 1954, the petitioner was not engaged in the trade or business of buying and selling land.
1Opinion of the Court
Simpson, Judge:
The respondent determined the following deficiencies in the petitioners’ Federal income taxes:
Docket No. Year Deficiency
4192-71_ 1967 $1,541.11
8092-71_ 1968 7,983.24
8092-71_-_ 1969 8,320.39
The issue for decision is whether certain sales of property by Robert L. Adam were sales of property held primarily for sale to customers in the ordinary course of his trade or business.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioners, Robert L. Adam and Judith W. Adam, husband and wife, resided in Falmouth, Maine, at the time of filing…
2Cases cited22 opinions
- Thrift v. CommissionerUnited States Tax Court · 1950
- Snell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1938
- Farley v. CommissionerUnited States Tax Court · 1946
- Eline Realty Co. v. CommissionerUnited States Tax Court · 1960
- Bedell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
17 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Westchester Dev. Co. v. CommissionerUnited States Tax Court · 1974
- Redwood Empire Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1977
- Guardian Indus. Corp. v. CommissionerUnited States Tax Court · 1991
- Gamble v. CommissionerUnited States Tax Court · 1977
- Thomas v. CommissionerUnited States Tax Court · 1981
18 more not listed; retrieve them via the Exa API.