Owen v. Commissioner of Internal Revenue

STRUM, Circuit Judge.

This is a petition to review a decision of the Tax Court which sustained a deficiency assessment in income taxes for 1944, entered by the Commissioner of Internal Revenue against petitioner Louise Owen.

Petitioner and her husband were engaged in the business of growing and selling citrus fruits in Florida. They owned several groves. They followed the customary practice in Florida of agreeing to sell fruit while it was still on the trees and to some extent immature, the buyer paying a fixed price per box as the fruit is picked, the seller allowing the fruit to remain on the…