Legal Opinion

Bildwell, Inc. v. Commissioner

United States Tax Court

Decided October 23, 1952No. Docket No. 36016Unpublished

Income: Ordinary or capital gain: Sec. 117 (j), I.R.C. - During 1945 petitioner completed construction of twenty-five residential defense houses with the purpose of immediately selling one-third and renting the others pursuant to certain restrictions. Petitioner sold twelve houses prior to October 1945 and within six months of their completion. In October 1945 restrictions on sales were revoked and petitioner continued its sales activities.

Read the full summary

Income: Ordinary or capital gain: Sec. 117 (j), I.R.C. - During 1945 petitioner completed construction of twenty-five residential defense houses with the purpose of immediately selling one-third and renting the others pursuant to certain restrictions. Petitioner sold twelve houses prior to October 1945 and within six months of their completion. In October 1945 restrictions on sales were revoked and petitioner continued its sales activities. Held, that eight houses held for more than six months and sold during the period of October 1945 to the close of fiscal year ending June 30, 1946, were…

1Opinion of the Court

Bildwell, Inc. v. Commissioner.

Bildwell, Inc. v. Commissioner

Docket No. 36016.

United States Tax Court

1952 Tax Ct. Memo LEXIS 61; 11 T.C.M. (CCH) 1018; T.C.M. (RIA) 52302;

October 23, 1952

Income: Ordinary or capital gain: Sec. 117 (j), I.R.C. - During 1945 petitioner completed construction of twenty-five residential defense houses with the purpose of immediately selling one-third and renting the others pursuant to certain restrictions. Petitioner sold twelve houses prior to October 1945 and within six months of their completion. In October 1945 restrictions on sales were revoked and petitioner…

2Cases cited2 opinions

  1. Winnick v. CommissionerUnited States Tax Court · 1951
  2. Victory Housing, Inc. v. CommissionerUnited States Tax Court · 1952

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API