Erickson v. Commissioner
United States Tax Court
Petitioners bought bulls and rented them for nominal amounts to neighboring dairy farmers for breeding purposes. The farmers using the bulls fed and cared for them at no expense to petitioners. After about a year and a half petitioner sold the bulls for slaughtering. The principal income was derived from the sale of the bulls.
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Petitioners bought bulls and rented them for nominal amounts to neighboring dairy farmers for breeding purposes. The farmers using the bulls fed and cared for them at no expense to petitioners. After about a year and a half petitioner sold the bulls for slaughtering. The principal income was derived from the sale of the bulls. Held, petitioners held the bulls for sale to customers in the ordinary course of their business and the income from the sales is taxable as ordinary income and not as a capital gain under section 117 (j) (1) of the Internal Revenue Code of 1939.
1Opinion of the Court
Albert T. Erickson and Stella E. Erickson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Erickson v. Commissioner
Docket No. 39677
United States Tax Court
23 T.C. 458; 1954 U.S. Tax Ct. LEXIS 23;
December 10, 1954, Filed
Decision will be entered for the respondent.
Petitioners bought bulls and rented them for nominal amounts to neighboring dairy farmers for breeding purposes. The farmers using the bulls fed and cared for them at no expense to petitioners. After about a year and a half petitioner sold the bulls for slaughtering. The principal income was derived from the sale of the…
2Cases cited10 opinions
- MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
- Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
- United States v. PfisterCourt of Appeals for the Eighth Circuit · 1953
- Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1944
- Delsing v. United StatesCourt of Appeals for the Fifth Circuit · 1951
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