(DOWNLOAD) "Reconstruction Finance Corp. v. Service Pipe Line Co." by United States Court of Appeals Tenth Circuit " eBook PDF Kindle ePub Free
eBook details
- Title: Reconstruction Finance Corp. v. Service Pipe Line Co.
- Author : United States Court of Appeals Tenth Circuit
- Release Date : January 29, 1952
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 71 KB
Description
This is an appeal from a decision of the Tax Court, holding that certain lots sold by petitioners during the taxable years 1944 and 1945, where "property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business" within the exclusionary clause of Section 117(a) (1) of the Internal Revenue Code, 26 U.S.C.A. § 117(a) (1). If the gain from the sale of these lots was derived in this manner, it constituted ordinary income taxable under Section 22(a), and not a capital gain taxable under Section 117(a) (1). Petitioners, residents of the State of New Mexico, are husband and wife, and all income involved is community income. The two cases were therefore consolidated for trial and disposition. A summary of Mauldins business activities is necessary to a determination of the issue presented.