Watson v. Commissioner
United States Tax Court
1. The petitioner and her brothers were the operating owners of an orange grove property comprising land, trees, a growing crop of oranges on the trees and other property employed in the operation, which they sold for a lump sum.
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1. The petitioner and her brothers were the operating owners of an orange grove property comprising land, trees, a growing crop of oranges on the trees and other property employed in the operation, which they sold for a lump sum. Held, that the growing crop of oranges was not real property used in the petitioner's trade or business within the meaning of that term as used in section 117 (j) of the Internal Revenue Code, and further that the crop constituted property held by petitioner primarily for sale to customers in the ordinary course of her trade or business and the gain realized upon the…
1Opinion of the Court
Ernest A. Watson and M. Gladys Watson, Petitioners, v. Commissioner of Internal Revenue, Respondent
Watson v. Commissioner
Docket No. 18856
United States Tax Court
15 T.C. 800; 1950 U.S. Tax Ct. LEXIS 27;
December 7, 1950, Promulgated
Decision will be entered under Rule 50.
1. The petitioner and her brothers were the operating owners of an orange grove property comprising land, trees, a growing crop of oranges on the trees and other property employed in the operation, which they sold for a lump sum. Held, that the growing crop of oranges was not real property used in the petitioner's trade or…
Also in this document: Dissent.
2Cases cited29 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Burnet v. HarmelSupreme Court of the United States · 1932
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Weiss v. WeinerSupreme Court of the United States · 1929
- Helvering v. HammelSupreme Court of the United States · 1941
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