Pritchett v. Commissioner
United States Tax Court
1. Held, certain parcels of real estate sold by petitioners in 1968 and 1969 were not held by petitioners primarily for sale to customers in the ordinary course of business and the profit realized on such sales is taxable as capital gain. 2. Held, further: The sale of two parcels of real estate by separate deeds to the same purchasers on the same day must be considered as two separate sales of real property for purposes of sec. 453 of the 1954 Code.
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1. Held, certain parcels of real estate sold by petitioners in 1968 and 1969 were not held by petitioners primarily for sale to customers in the ordinary course of business and the profit realized on such sales is taxable as capital gain. 2. Held, further: The sale of two parcels of real estate by separate deeds to the same purchasers on the same day must be considered as two separate sales of real property for purposes of sec. 453 of the 1954 Code. So considered, the sale of one of the parcels does not qualify for installment reporting of income under sec. 453. 3. Held, further, petitioners…
1Opinion of the Court
Richard H. Pritchett and Virginia B. Pritchett, Petitioners v. Commissioner of Internal Revenue, Respondent
Pritchett v. Commissioner
Docket No. 8923-72
United States Tax Court
63 T.C. 149; 1974 U.S. Tax Ct. LEXIS 24;
November 13, 1974, Filed
Decision will be entered under Rule 155.
1. Held, certain parcels of real estate sold by petitioners in 1968 and 1969 were not held by petitioners primarily for sale to customers in the ordinary course of business and the profit realized on such sales is taxable as capital gain.
2. Held, further: The sale of two parcels of real estate by separate deeds to the…
2Cases cited27 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- Enoch v. CommissionerUnited States Tax Court · 1972
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- American Properties, Inc. v. CommissionerUnited States Tax Court · 1957
- Thrift v. CommissionerUnited States Tax Court · 1950
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