Legal Opinion

Ambassador, Inc. v. Commissioner

United States Tax Court

Decided September 30, 1952No. Docket No. 29629Unpublished

Held, on the facts, petitioner's predecessor Development Company, was engaged during 1938 in a business of buying and selling real estate, and that a particular property sold in 1938, which had been acquired in 1935 at a foreclosure sale, was held by Development primarily for sale to customers in the ordinary course of its trade or business within Section 117, Internal Revenue Code.

1Opinion of the Court

Ambassador, Inc. (Formerly 14th Street Development Company) v. Commissioner.

Ambassador, Inc. v. Commissioner

Docket No. 29629.

United States Tax Court

1952 Tax Ct. Memo LEXIS 75; 11 T.C.M. (CCH) 974; T.C.M. (RIA) 52289;

September 30, 1952

Held, on the facts, petitioner's predecessor Development Company, was engaged during 1938 in a business of buying and selling real estate, and that a particular property sold in 1938, which had been acquired in 1935 at a foreclosure sale, was held by Development primarily for sale to customers in the ordinary course of its trade or business within Section 117,…

2Cases cited4 opinions

  1. Winnick v. CommissionerUnited States Tax Court · 1951
  2. Black v. CommissionerUnited States Board of Tax Appeals · 1941
  3. Goodman v. CommissionerUnited States Board of Tax Appeals · 1939
  4. Queensboro Corp. v. CommissionerUnited States Board of Tax Appeals · 1942

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