Thompson v. Commissioner
United States Tax Court
1. Lots in a platted subdivision sold by petitioner in the taxable years 1957 and 1958 and those sold in a prior year on an installment basis on which collections were being made in these taxable years, were held primarily for sale to customers in the ordinary course of petitioner's trade or business and the gains therefrom constitute ordinary income. 2. Where petitioner has elected to report Commodity Credit Corporation loans as income in the year of receipt under sec. 77,…
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1. Lots in a platted subdivision sold by petitioner in the taxable years 1957 and 1958 and those sold in a prior year on an installment basis on which collections were being made in these taxable years, were held primarily for sale to customers in the ordinary course of petitioner's trade or business and the gains therefrom constitute ordinary income. 2. Where petitioner has elected to report Commodity Credit Corporation loans as income in the year of receipt under sec. 77, I.R.C. 1954, he must include in income all amounts so received even though the commodities pledged to secure some of the…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ income tax for the calendar years 1957 and 1958 in the amounts of $10,882.37 and $21,262.43, respectively. The issues for decision are whether petitioners realized long-term capital gain on the sales of various lots in the years 1957 and 1958 and whether Commodity Credit Corporation loans totaling $15,486.06 made to petitioners in 1958 resulted in taxable income to them during 1958.
FINDINGS OF FACT.
Petitioners, husband and wife residing in Borger, Hutchinson County, Texas, filed their joint income tax returns for the years 1957…
2Cases cited20 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Thrift v. CommissionerUnited States Tax Court · 1950
- MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
- Mauldin v. CommissionerUnited States Tax Court · 1951
- Farley v. CommissionerUnited States Tax Court · 1946
15 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Buono v. CommissionerUnited States Tax Court · 1980
- Carl E. And Paula Koch, and Cross-Appellants v. United States of America, and Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1972
- Williford v. CommissionerUnited States Tax Court · 1994
- Turner v. CommissionerUnited States Tax Court · 1974
- Asmussen v. United StatesDistrict Court, D. South Dakota · 1984
18 more not listed; retrieve them via the Exa API.