Legal Opinion
Pacific Homes, Inc., a Corporation v. United States
Court of Appeals for the Ninth Circuit
Decided February 21, 1956No. 14732PublishedCited by 13 opinions
1Opinion of the Court
LEMMON, Circuit Judge.
The sovereign is not to be frustrated in the replenishment of its fisc by the finespun arguments advanced by the appellant. When the taxpayer itself, in its income tax returns, has repeatedly described its business as that of renting and selling homes; when it has developed a crafty technique whereby it can quicken its sales; when, in three other tracts, not here in issue, the appellant sold all its houses; when its board of directors formally ratified its previous sales and authorized future ones; when, in sum, the appellant has generally sold houses whenever it had the…
2Cases cited5 opinions
- Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Nathan D. Goldberg and S. E. Wood, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- A B C Brewing Corporation (Formerly Aztec Brewing Co.), a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Homann v. CommissionerCourt of Appeals for the Ninth Circuit · 1956
3Cited by13 opinions
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Ferrando v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Harold Wener v. Commissioner of Internal Revenue, Molly Wener v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- The Pennroad Corporation and Affiliated Companies v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Pool v. CommissionerCourt of Appeals for the Ninth Circuit · 1957
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