Williamson v. Bowers

WARING, District Judge.

The plaintiff has brought suit claiming a refund on income tax paid by him and the matter involved is whether certain transactions in regard to the disposition of an amount of cotton should be regarded as ordinary business transactions in which the profits must be treated as annual income or whether the transaction comes within the purview of the statute which allows the treatment of certain transactions as “capital assets”. If the taxpayer’s contention is correct that the cotton involved was held by him as contemplated by the statute for the purpose of an investment…