Legal Opinion

Good v. Commissioner

United States Tax Court

Decided April 26, 1951No. Docket No. 24552PublishedCited by 2 opinions

Held, since petitioner was using the property in question in a trade or business, the loss from its sale in 1944 is deductible in full under section 23 (e) of the Internal Revenue Code.

1Opinion of the Court

OPINION.

Hill, Judge:

The respondent contends that the loss from petitioner’s sale of the land in question constituted a loss from the sale of a capital asset. The petitioner, on the other hand, contends first that he held the 20-acre tract in question primarily for sale in the ordinary course of his trade or business and, second, that “the 20-acre parcel * * * was ‘real property used in the trade or business of the taxpayer’ within the meaning of Internal Revenue Code Section 117 (a) (1).”

We ágree with the petitioner that the property in question was “real property used in the trade or…

2Cases cited5 opinions

  1. Hazard v. CommissionerUnited States Tax Court · 1946
  2. Campbell v. CommissionerUnited States Tax Court · 1945
  3. Wright v. CommissionerUnited States Tax Court · 1947
  4. Jamison v. CommissionerUnited States Tax Court · 1947
  5. Crawford v. CommissionerUnited States Tax Court · 1951

3Cited by2 opinions

  1. Good v. CommissionerUnited States Tax Court · 1951
  2. Miller v. CommissionerUnited States Tax Court · 1982

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