Wardman Real Estate Inv. Corp. v. District of Columbia

GRONER, G J.

This is a petition to review a decision of the District of Columbia Board of Tax Appeals. Petitioner is a Virginia corporation, with its principal place of business in the District of Columbia. Its appeal to us is from the assessment of additional income tax by the Assessor of the District in holding the profits of the sale of certain real estate to be ordinary income and therefore taxable. The applicable statute is § 6(b) of Title II, of the District of Columbia Revenue Act of 1939, 53 Stat. 1091, § 47— 1506(b), D.C.Code 1940, and provides that:

“Gains and losses from the sale or…