Legal Opinion
Browne v. United States
United States Court of Claims
Decided February 18, 1966No. 70-61; No. 71-61; No. 72-61PublishedCited by 13 opinions
1Opinion of the Court
Per Curiam :
This is another income tax case in which the ultimate issue is whether or not the taxpayers held certain real property primarily for sale to customers in the ordinary course of business. This is a question which must be decided on the particular facts and circumstances. See, e.g., Miller v. United States, 168 Ct. Cl. 498, 504, 339 F. 2d 661, 663-64 (1964); Garrett v. United States, 128 Ct. Cl. 100, 104, 120 F. Supp. 193, 195-96 (1954); Bauschard v. Commissioner, 279 F. 2d 115, 117-18 (C.A. 6, 1960). The facts in this case are *525set forth in the findings made by Chief Trial…
2Cases cited11 opinions
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Raymond Bauschard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
- Robert Thomas and Susan B. Thomas v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Patterson v. BelcherCourt of Appeals for the Fifth Circuit · 1962
- Garrett v. United StatesUnited States Court of Claims · 1954
6 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Todd Tibbals and Helen A. Tibbals v. The United StatesUnited States Court of Claims · 1966
- Royce W. Brown and Patty L. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- John Nadalin and Mary Nadalin v. The United StatesUnited States Court of Claims · 1966
- Boyer v. CommissionerUnited States Tax Court · 1972
- Bert Crosswhite and Virginia Crosswhite v. The United StatesUnited States Court of Claims · 1966
8 more not listed; retrieve them via the Exa API.