Phipps v. Commissioner
United States Board of Tax Appeals
1. The cost of the part of the real estate involved in this case, which was sold in the years 1922 and 1923, was, under the 1921 Act, a capital investment, and the profits made thereon are liable to tax under section 206(b) of the 1921 Act. 2. Such of said real estate as was sold in 1924 and subsequent years constituted, under the 1924 Act, property held primarily for sale in the course of the taxpayer's business, and the profits realized thereon are taxable under sections…
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1. The cost of the part of the real estate involved in this case, which was sold in the years 1922 and 1923, was, under the 1921 Act, a capital investment, and the profits made thereon are liable to tax under section 206(b) of the 1921 Act. 2. Such of said real estate as was sold in 1924 and subsequent years constituted, under the 1924 Act, property held primarily for sale in the course of the taxpayer's business, and the profits realized thereon are taxable under sections 210 and 211 of the Revenue Act of 1924.
1Opinion of the Court
JOHN S. PHIPPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
AMY GUEST, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
HENRY C. PHIPPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Phipps v. Commissioner
Docket Nos. 26038-26040, 33203-33205.
United States Board of Tax Appeals
19 B.T.A. 1293; 1930 BTA LEXIS 2235;
May 29, 1930, Promulgated
1. The cost of the part of the real estate involved in this case, which was sold in the years 1922 and 1923, was, under the 1921 Act, a capital investment, and the profits made thereon are liable to tax under section…
2Cases cited1 opinion
- Phipps v. CommissionerUnited States Board of Tax Appeals · 1930