Hillard v. Commissioner
United States Tax Court
Held, upon this record, sales of rental vehicles which had been leased for about one-fourth of their useful life were sales of property held primarily for sale to customers in the ordinary course of petitioner's trade or business, and gains from such sales are taxable as ordinary income. Sec. 117(j)(1)(B), I.R.C. 1939.
1Opinion of the Court
Charlie Hillard and Mary Jane Hillard, Petitioners, v. Commissioner of Internal Revenue, Respondent
Hillard v. Commissioner
Docket No. 61604
United States Tax Court
31 T.C. 961; 1959 U.S. Tax Ct. LEXIS 244;
February 9, 1959, Filed
Decision will be entered under Rule 50.
Held, upon this record, sales of rental vehicles which had been leased for about one-fourth of their useful life were sales of property held primarily for sale to customers in the ordinary course of petitioner's trade or business, and gains from such sales are taxable as ordinary income. Sec. 117(j)(1)(B), I.R.C. 1939.
George S.…
2Cases cited8 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Philber Equipment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
- Philber Equip. Corp. v. Comm'rUnited States Tax Court · 1955
- Williamson v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
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