Estate of Palmer v. Commissioner

OPINION.

Eaum, Judge:

The conclusion that the business of Greenbrier Farms was not the business of Palmer follows of necessity from such deci- - sions as Jan G. J. Boissevain, 17 T. C. 325; A. Kingsley Ferguson, 16 T. C. 1248; Dalton v. Bowers, 287 U. S. 404; Burnet v. Clark, 287 U. S. 410; and Deputy v. duPont, 308 U. S. 488, 493-494. True, a different result has been reached in some exceptional situations where the taxpayer’s activities in making loans to a number of corporations and financing various enterprises have themselves been regarded as so extensive as to constitute a business. Cf.…