Legal Opinion
Stephen G. Achong v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 25, 1957No. 15229PublishedCited by 34 opinions
1Opinion of the Court
DENMAN, Chief Judge.
Achong petitions for review of a decision of the Tax Court holding that the proceeds which he received from the sale of lots of a subdivision of his real estate in Honolulu, Hawaii in 1946 and 1947 were ordinary income rather than capital gain under Section 117, Internal Revenue Code of 1939, 26 U.S.C.A. § 117, and assessing income tax deficiencies against him for $10,799.76 and $1,-105.69 respectively for the two years.
Petitioner’s sole contention is that the facts do not support the court’s finding of fact and conclusion of law that:
“The lots in question were lands held…
2Cases cited5 opinions
- Arthur W. Smith and Mrs. Arthur W. Smith v. Charles H. Dunn, Formerly Acting Collector of Internal RevenueCourt of Appeals for the Fifth Circuit · 1955
- Ehrman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1941
- Richards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1936
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Curtis Company (Formerly Curtis Engineering Company) v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
3Cited by34 opinions
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Curphey v. CommissionerUnited States Tax Court · 1980
- Raymond Bauschard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
- Estate of Finder v. CommissionerUnited States Tax Court · 1961
- Pool v. CommissionerCourt of Appeals for the Ninth Circuit · 1957
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