Factoria Land Co. v. Commissioner
United States Tax Court
Held, that petitioner was engaged in carrying on or doing business during 1940 and is subject to the declared value excess-profits tax under Section 600, I.R.C., as amended. Held, that property sold in 1940 was held primarily for sale to customers in ordinary course of petitioner's business within Section 117 (a) (1), I.R.C., as amended, and the gain realized was ordinary income subject to excess-profits tax under Section 711, I.R.C., as amended.
1Opinion of the Court
Factoria Land Company v. Commissioner.
Factoria Land Co. v. Commissioner
Docket No. 2702.
United States Tax Court
1947 Tax Ct. Memo LEXIS 289; 6 T.C.M. (CCH) 234; T.C.M. (RIA) 47051;
February 28, 1947
Held, that petitioner was engaged in carrying on or doing business during 1940 and is subject to the declared value excess-profits tax under Section 600, I.R.C., as amended.
Held, that property sold in 1940 was held primarily for sale to customers in ordinary course of petitioner's business within Section 117 (a) (1), I.R.C., as amended, and the gain realized was ordinary income subject to…
2Cases cited9 opinions
- Von Baumbach v. Sargent Land Co.Supreme Court of the United States · 1917
- United States v. Emery, Bird, Thayer Realty Co.Supreme Court of the United States · 1915
- McCoach v. Minehill & Schuylkill Haven RailroadSupreme Court of the United States · 1913
- Zonne v. Minneapolis SyndicateSupreme Court of the United States · 1911
- Edwards v. Chile Copper Co.Supreme Court of the United States · 1926
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