Belcher v. Commissioner
United States Tax Court
1. Allendale tract was not held by the Belcher partnership primarily for sale to customers in the ordinary course of its trade or business in 1953, and, to the extent of their distributive shares thereof, gain on the sale of certain parcels therefrom by the partnership was taxable as capital gain rather than ordinary income to the partners. 2. Partnership was in the business of selling timber in 1953 and timber sold by the partnership to the Belcher corporation in 1953 was…
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1. Allendale tract was not held by the Belcher partnership primarily for sale to customers in the ordinary course of its trade or business in 1953, and, to the extent of their distributive shares thereof, gain on the sale of certain parcels therefrom by the partnership was taxable as capital gain rather than ordinary income to the partners. 2. Partnership was in the business of selling timber in 1953 and timber sold by the partnership to the Belcher corporation in 1953 was held primarily for sale to its customers in the ordinary course of its trade or business. Partners' distributive share of…
1Opinion of the Court
William Albert Belcher, Jr., and Nell Vandergrift Belcher, Trustee, et al. 1 v. Commissioner.
Belcher v. Commissioner
Docket Nos. 83206, 83208-83211.
United States Tax Court
T.C. Memo 1965-1; 1965 Tax Ct. Memo LEXIS 330; 24 T.C.M. (CCH) 1; T.C.M. (RIA) 65001;
January 8, 1965
1. Allendale tract was not held by the Belcher partnership primarily for sale to customers in the ordinary course of its trade or business in 1953, and, to the extent of their distributive shares thereof, gain on the sale of certain parcels therefrom by the partnership was taxable as capital gain rather than ordinary income to…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Amos v. CommissionerUnited States Tax Court · 1964
- Tauber v. CommissionerUnited States Tax Court · 1955
- Shomaker v. CommissionerUnited States Tax Court · 1962
6 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Mladinich v. CommissionerUnited States Tax Court · 1969