Farry v. Commissioner
United States Tax Court
Petitioner Nelson A. Farry, who for a good many years has been in the insurance and real estate business, developed certain subdivisions in the city of Dallas, Texas, and constructed residences thereon, and in the taxable years he sold some of them at a profit. These profits he returned as ordinary income.
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Petitioner Nelson A. Farry, who for a good many years has been in the insurance and real estate business, developed certain subdivisions in the city of Dallas, Texas, and constructed residences thereon, and in the taxable years he sold some of them at a profit. These profits he returned as ordinary income. Petitioner also during the course of the years acquired other properties, not located in these subdivisions, primarily for investment purposes and collected rentals thereon. During the taxable years he sold some of the rental properties and returned the profits therefrom as long term…
1Opinion of the Court
OPINION.
Black, Judge:
In these proceedings we have no issue as to the amounts of petitioners’ income, which, as shown in our findings of fact, was from several sources. The only question is whether petitioners are entitled to report the profits from the sales of certain rental properties as long term capital gains and taxable on only 50 per cent thereof, as petitioners contend, or whether they are taxable on 100 per cent thereof as the Commissioner has determined. In addition to the income which petitioners reported from the sale of these rental properties, they also reported gross income on…
2Cases cited3 opinions
- Hazard v. CommissionerUnited States Tax Court · 1946
- Wright v. CommissionerUnited States Tax Court · 1947
- Jamison v. CommissionerUnited States Tax Court · 1947
3Cited by9 opinions
- McGah v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
- SEC CORPORATION v. United StatesDistrict Court, S.D. New York · 1956
- Galena Oaks Corp. v. ScofieldDistrict Court, S.D. Texas · 1953
- Cedarburg Fox Farms, Inc. v. United States of America, Cedarburg Fox Farms, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1960
- Nolla v. Secretario de HaciendaSupreme Court of Puerto Rico · 1954
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