Clinton Park Development Co. v. Commissioner of Internal Revenue

HOLMES, Circuit Judge.

The Clinton Park Development Company, a corporation, was organized to construct approximately 533 houses. The money necessary for the financing of this venture was obtained from loans guaranteed by the Federal Housing Administration, the financing expenses of which were paid by said company. During the year 1942, 507 of these houses were sold to purchasers under sales contracts, the terms of which required the purchasers to pay the F. H. A. loan applicable to the particular property and also another comparatively small indebtedness referred to as the equity loan. The…