Legal Opinion

Sapphire Lands, Inc. v. Commissioner

United States Tax Court

Decided February 1, 1973No. Docket Nos. 1587-70, 1588-70Unpublished

The petitioners were organized to subdivide and develop land, and from 1958 to 1965, they held certain land for the purpose of subdividing it and selling lots at retail. In 1966, such land was rezoned, and plans for subdividing the land were adopted. In 1967, four parcels of the land were sold, and in 1968, eight parcels were sold.

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The petitioners were organized to subdivide and develop land, and from 1958 to 1965, they held certain land for the purpose of subdividing it and selling lots at retail. In 1966, such land was rezoned, and plans for subdividing the land were adopted. In 1967, four parcels of the land were sold, and in 1968, eight parcels were sold. Held, the petitioners have failed to show that during 1967 they were not holding the land primarily for sale to customers in the ordinary course of business.

1Opinion of the Court

SAPPHIRE LANDS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

GARNET LANDS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Sapphire Lands, Inc. v. Commissioner

Docket Nos. 1587-70, 1588-70.

United States Tax Court

T.C. Memo 1973-23; 1973 Tax Ct. Memo LEXIS 264; 32 T.C.M. (CCH) 82; T.C.M. (RIA) 73023;

February 1, 1973, Filed

The petitioners were organized to subdivide and develop land, and from 1958 to 1965, they held certain land for the purpose of subdividing it and selling lots at retail. In 1966, such land was rezoned, and plans for subdividing the land were…

2Cases cited17 opinions

  1. Malat v. RiddellSupreme Court of the United States · 1966
  2. Thrift v. CommissionerUnited States Tax Court · 1950
  3. MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
  4. Mauldin v. CommissionerUnited States Tax Court · 1951
  5. Eline Realty Co. v. CommissionerUnited States Tax Court · 1960

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