Dressen v. Commissioner
United States Tax Court
Gain from Sales of Lots -- Capital Gain. -- The petitioner purchased country lots in 1931 as an investment. He held the lots for 15 years. Some of the lots were sold in 1946 and 1947. Held, under the facts, that the lots were not held primarily for sale to customers in the ordinary course of petitioner's business within section 117 (a) (1), I. R. C., and that gain realized from sales in 1947 is taxable as long term capital gain.
1Opinion of the Court
Martin Dressen, Petitioner, v. Commissioner of Internal Revenue, Respondent
Dressen v. Commissioner
Docket No. 32348
United States Tax Court
17 T.C. 1443; 1952 U.S. Tax Ct. LEXIS 258;
March 6, 1952, Promulgated
Decision will be entered for the petitioner.
Gain from Sales of Lots -- Capital Gain. -- The petitioner purchased country lots in 1931 as an investment. He held the lots for 15 years. Some of the lots were sold in 1946 and 1947. Held, under the facts, that the lots were not held primarily for sale to customers in the ordinary course of petitioner's business within section 117 (a) (1), I. R.…
2Cases cited19 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Thrift v. CommissionerUnited States Tax Court · 1950
- Mauldin v. CommissionerUnited States Tax Court · 1951
- Farley v. CommissionerUnited States Tax Court · 1946
- Ehrman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1941
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