Darby Investment Corporation v. Commissioner or Internal Revenue

Darby Investment Corporation petitions this Court for a review of the decision of the Tax Court of the United States redetermining deficiencies in its income taxes for its fiscal years ending August 31, 1956 and 1957. The taxpayer is a corporation organized under the laws of the state of Michigan and during the time pertinent to this case was engaged in the business of buying land contracts at a discount in Michigan.

Seventy-six contracts are involved here which were purchased by the petitioner during its fiscal years 1956 and 1957. Approximately ninety percent of these contracts were…