Legal Opinion

Wilson v. Commissioner

United States Tax Court

Decided July 25, 1977No. Docket Nos. 7001-71, 3981-72, 3994-72Unpublished

Held, whether petitioners' capital asset is determined to be real estate or an option to purchase real estate, the holding period of the asset was not more than six months and the sale thereof resulted in short-term capital gain.

1Opinion of the Court

J. KENYON WILSON, JR. AND MARY H. WILSON, ET AL, 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

Wilson v. Commissioner

Docket Nos. 7001-71, 3981-72, 3994-72.

United States Tax Court

T.C. Memo 1977-228; 1977 Tax Ct. Memo LEXIS 207; 36 T.C.M. (CCH) 948; T.C.M. (RIA) 770228;

July 25, 1977, Filed

Held, whether petitioners' capital asset is determined to be real estate or an option to purchase real estate, the holding period of the asset was not more than six months and the sale thereof resulted in short-term capital gain.

Charles C. Shaw, Jr. for the petitioners.

Robert A. Johnson, for…

2Cases cited16 opinions

  1. Reily v. CommissionerUnited States Tax Court · 1969
  2. Elks v. . Insurance CoSupreme Court of North Carolina · 1912
  3. Yaggy v. BVD COMPANYCourt of Appeals of North Carolina · 1970
  4. Wichita Terminal Elevator Co. v. CommissionerUnited States Tax Court · 1946
  5. Tuttle v. Junior Building Corp.Supreme Court of North Carolina · 1948

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