Beauchamp & Brown Groves Co. v. Commissioner
United States Tax Court
Held: That liquidation under the provisions of section 337, I.R.C. 1954, does not prevent the operation of section 268, I.R.C. 1954, to disallow deductions attributable to the production of an unharvested crop which is sold with the land and considered as "property used in the trade or business" under section 1231, I.R.C. 1954. Petitioner's contention that a sale of land with an unharvested crop must result in recognized gain before the unharvested crop can be characterized…
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Held: That liquidation under the provisions of section 337, I.R.C. 1954, does not prevent the operation of section 268, I.R.C. 1954, to disallow deductions attributable to the production of an unharvested crop which is sold with the land and considered as "property used in the trade or business" under section 1231, I.R.C. 1954. Petitioner's contention that a sale of land with an unharvested crop must result in recognized gain before the unharvested crop can be characterized by section 1231 is rejected.
1Opinion of the Court
Beauchamp & Brown Groves Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Beauchamp & Brown Groves Co. v. Commissioner
Docket No. 2871-62
United States Tax Court
44 T.C. 117; 1965 U.S. Tax Ct. LEXIS 94;
April 28, 1965, Filed April 28, 1965, Filed
Decision will be entered for the respondent.
Held: That liquidation under the provisions of section 337, I.R.C. 1954, does not prevent the operation of section 268, I.R.C. 1954, to disallow deductions attributable to the production of an unharvested crop which is sold with the land and considered as "property used in the trade or…
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- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Harrison v. Northern Trust Co.Supreme Court of the United States · 1943
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