Legal Opinion

Dr. P. Phillips & Son, Inc. v. Commissioner

United States Tax Court

Decided May 25, 1953No. Docket No. 24505Published

Petitioner, a Florida, citrus fruit producer, realized income, abnormal in amount, in the taxable year from the sale of its citrus crop.

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Petitioner, a Florida, citrus fruit producer, realized income, abnormal in amount, in the taxable year from the sale of its citrus crop. It claimed relief from excess profits tax under section 721 (a) (2) (C) of the Internal Revenue Code upon the ground that it had a separate class of income which resulted from the development of tangible property, or, that the income from its citrus operations constituted a class of income under the general provisions of section 721 (a) (2). Respondent denied petitioner relief under section 721. Held, assuming that petitioner had a class of income, which was…

1Opinion of the Court

Dr. P. Phillips and Sons, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Dr. P. Phillips & Son, Inc. v. Commissioner

Docket No. 24505

United States Tax Court

20 T.C. 435; 1953 U.S. Tax Ct. LEXIS 147;

May 25, 1953, Promulgated

Decision will be entered for the respondent.

Petitioner, a Florida, citrus fruit producer, realized income, abnormal in amount, in the taxable year from the sale of its citrus crop. It claimed relief from excess profits tax under section 721 (a) (2) (C) of the Internal Revenue Code upon the ground that it had a separate class of income which resulted from the…

2Cases cited7 opinions

  1. W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
  2. Soabar Co. v. CommissionerUnited States Tax Court · 1946
  3. Morrisdale Coal Mining Co. v. CommissionerUnited States Tax Court · 1949
  4. Primas Groves, Inc. v. CommissionerUnited States Tax Court · 1950
  5. Graves Bros. Co. v. CommissionerUnited States Tax Court · 1952

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