Garden Homes Co. v. Commissioner

1. Where a corporate taxpayer purchased land and platted and improved the same, constructed homes thereon, leased the same to its common stockholders under a subscription for stock and lease agreement providing for payment of rental, and later sold such homes to its stockholders for cash or on land contract and in its books of account entered certain payments received from such stockholders as rents, profits on real estate sales, etc., and the Commissioner computed taxable income from such income accounts, and in the absence of evidence as to the number of shares of common stock issued and…