Estate of Collins v. Commissioner
United States Tax Court
Taxpayers were in the business of developing subdivisions of real estate and selling lots therein to builders. In developing the subdivisions here in question it was necessary for taxpayers to arrange and pay for a sewage disposal system servicing the residential units in order to induce people to buy lots therein.
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Taxpayers were in the business of developing subdivisions of real estate and selling lots therein to builders. In developing the subdivisions here in question it was necessary for taxpayers to arrange and pay for a sewage disposal system servicing the residential units in order to induce people to buy lots therein. By various conveyances, trust deeds, and agreements, the owners of the lots were given an equitable interest in the system, a corporation owned by taxpayers was given the right and duty to operate the system for annual charges to be paid by the lot owners which were abnormally low…
1Opinion of the Court
OPINION.
Kern, Judge:
The first issue involved in the instant case is whether respondent erred in his determination “that the 68 lots in Unit 2, Rodney Subdivision, sold * * * in 1951 were held primarily for sale to customers in the ordinary course of a trade or business within the meaning of section ITT (a) (1) of the Internal Revenue Code of 1989 and that the entire gain realized from the sale of these lots is taxable as ordinary income.”
Petitioners, relying on the fact that title to the subdivision was taken in the name of Lila T. Collins, a housewife, contend that it was purchased for her…
2Cases cited2 opinions
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
- The Colony, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1957
3Cited by8 opinions
- Commissioner of Internal Revenue v. George W. Offutt, Iii, and Jane P. Offutt, and Pimmit Development CorporationCourt of Appeals for the Fourth Circuit · 1964
- Willow Terrace Development Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- Eggert v. CommissionerUnited States Tax Court · 1977
- Dahling v. CommissionerUnited States Tax Court · 1988
- Estate of Collins v. CommissionerUnited States Tax Court · 1958
3 more not listed; retrieve them via the Exa API.