Williamson v. Commissioner
United States Tax Court
Petitioner owned land which was farmed by sharecroppers; he also owned and operated a cotton gin, a cotton warehouse, two cotton seed warehouses, and a mercantile store which sold fertilizer and other supplies to nearby farmers. As part of his operations, he purchased annually from the farmers the bulk of the cotton that was baled at his gin.
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Petitioner owned land which was farmed by sharecroppers; he also owned and operated a cotton gin, a cotton warehouse, two cotton seed warehouses, and a mercantile store which sold fertilizer and other supplies to nearby farmers. As part of his operations, he purchased annually from the farmers the bulk of the cotton that was baled at his gin. During each of the tax years he resold such cotton on "call" arrangements with certain cotton merchants, whereby the ultimate sales price was determined by reference to market prices as of some future date when petitioner notified the purchaser to fix…
1Opinion of the Court
FINDINGS OF'FACT AND OPINION.
Ratjm, Judge:
The petitioners, husband and wife, reside in Norway, South Carolina. The income tax returns involved, for the years 1945 and 1946, were filed with the collector of internal revenue for the district of South Carolina. The Commissioner asserted deficiencies for each of these years in the amounts of $2,725.59, and $35,887.59, respectively. John W. Williamson will be referred to hereinafter as petitioner.
The only question in issue is whether the profit derived from the sale of cotton owned by petitioner in each of the years shall be taxed as ordinary…
2Cited by15 opinions
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- Heebner v. CommissionerUnited States Tax Court · 1959
- Louisiana Western Lumber Co. v. CommissionerUnited States Tax Court · 1954
- Patterson v. HightowerCourt of Appeals for the Fifth Circuit · 1957
- Hillard v. CommissionerUnited States Tax Court · 1959
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