Sykes v. Commissioner
United States Tax Court
In 1967 and 1968 petitioner, a farmer, sold alfalfa leafcutter bee larvae in bee boards. Some larvae were raised by petitioner and others were purchased for resale. Petitioner reported the amounts received from the sale of purchased bee larvae as ordinary income and the amounts received from the sale of the raised bee larvae as capital gains.
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In 1967 and 1968 petitioner, a farmer, sold alfalfa leafcutter bee larvae in bee boards. Some larvae were raised by petitioner and others were purchased for resale. Petitioner reported the amounts received from the sale of purchased bee larvae as ordinary income and the amounts received from the sale of the raised bee larvae as capital gains. Held, that (1) the raised bee larvae were held primarily for sale to customers in the ordinary course of petitioner's business and do not qualify as a capital asset entitled to preferential long-term capital gain treatment under sec. 1221, I.R.C. 1954;…
1Opinion of the Court
Charles A. Sykes and Marjorie M. Sykes, Petitioners v. Commissioner of Internal Revenue, Respondent
Sykes v. Commissioner
Docket No. 7386-70
United States Tax Court
57 T.C. 618; 1972 U.S. Tax Ct. LEXIS 182;
February 15, 1972, Filed
Decision will be entered under Rule 50.
In 1967 and 1968 petitioner, a farmer, sold alfalfa leafcutter bee larvae in bee boards. Some larvae were raised by petitioner and others were purchased for resale. Petitioner reported the amounts received from the sale of purchased bee larvae as ordinary income and the amounts received from the sale of the raised bee larvae as…
2Cases cited12 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Malat v. RiddellSupreme Court of the United States · 1966
- Patterson v. BelcherCourt of Appeals for the Fifth Circuit · 1962
- The Pennroad Corporation and Affiliated Companies v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
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