Crabtree v. Commissioner
United States Tax Court
In 1947, 1948, 1949, and the fiscal year ending March 31, 1950, petitioners realized gains from the sale of certain units of a defense-housing project and unimproved lots. 1. Held, that all of the houses and one of the unimproved lots were held primarily for investment and were entitled to capital-gains treatment under section 117 of the Internal Revenue Code. 2. Held, further, that the remaining unimproved lots were held primarily for sale to customers in the ordinary…
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In 1947, 1948, 1949, and the fiscal year ending March 31, 1950, petitioners realized gains from the sale of certain units of a defense-housing project and unimproved lots. 1. Held, that all of the houses and one of the unimproved lots were held primarily for investment and were entitled to capital-gains treatment under section 117 of the Internal Revenue Code. 2. Held, further, that the remaining unimproved lots were held primarily for sale to customers in the ordinary course of trade or business and were not entitled to such capital-gains treatment.
1Opinion of the Court
Walter R. Crabtree, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Crabtree v. Commissioner
Docket Nos. 36284, 36285, 36286, 36287
United States Tax Court
20 T.C. 841; 1953 U.S. Tax Ct. LEXIS 87;
July 22, 1953, Promulgated
Decision will be entered under Rule 50.
In 1947, 1948, 1949, and the fiscal year ending March 31, 1950, petitioners realized gains from the sale of certain units of a defense-housing project and unimproved lots.
1. Held, that all of the houses and one of the unimproved lots were held primarily for investment and were entitled to capital-gains treatment under…
2Cases cited12 opinions
- Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
- Commissioner of Internal Revenue v. BoeingCourt of Appeals for the Ninth Circuit · 1939
- King v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Victory Housing No. 2, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1953
- Greene v. CommissionerCourt of Appeals for the Fifth Circuit · 1944
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