Collins v. Commissioner
United States Tax Court
Petitioners entered into an agreement to sell fill dirt from their land. The agreement set forth the areas from which the dirt was to be removed, estimated the amount of dirt in place in these areas, and imposed upon the buyer of the dirt an obligation to remove and pay for all of the dirt in place situated in these areas. Held, petitioners' profit from the sale of fill dirt is taxable as long-term capital gain.
1Opinion of the Court
Wayman A. Collins and Helen R. Collins, Petitioners v. Commissioner of Internal Revenue, Respondent
Collins v. Commissioner
Docket No. 3973-69
United States Tax Court
56 T.C. 1074; 1971 U.S. Tax Ct. LEXIS 79;
August 12, 1971, Filed
Decision will be entered for the petitioners.
Petitioners entered into an agreement to sell fill dirt from their land. The agreement set forth the areas from which the dirt was to be removed, estimated the amount of dirt in place in these areas, and imposed upon the buyer of the dirt an obligation to remove and pay for all of the dirt in place situated in these areas.…
2Cases cited15 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Commissioner v. Southwest Exploration Co.Supreme Court of the United States · 1956
- Crowell Land and Mineral Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Arthur S. Barker and Alberta C. Barker v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Dann v. CommissionerUnited States Tax Court · 1958
10 more not listed; retrieve them via the Exa API.