AL Carter Co. v. Commissioner of Internal Revenue

HOLMES, Circuit Judge.

Petitioner, a Texas corporation, was for many years engaged at Beaumont, Texas, in the lumber business and in financing the building of houses. It furnished to customers who desired to build homes the necessary materials and funds, taking a first-lien note, payable in installments, for the indebtedness due. During the depression years following 1929, many notes became delinquent, and petitioner frequently found it necessary to foreclose its lien to protect its investment. It thus acquired several hundred houses, which were kept in repair and rented until a satisfactory…