J. C. NICHOLS LAND CO. v. COMMISSIONER OF INT. REV.

No. 9465.

65 F.2d 437 (1933)

J. C. NICHOLS LAND CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Eighth Circuit.

May 11, 1933.


Attorney(s) appearing for the Case

Phil D. Morelock, of Kansas City, Mo. (Perry W. Shrader and Shouse, Doolittle, Morelock & Shrader, all of Kansas City, Mo., on the brief), for petitioner.

Helen R. Carloss, Sp. Asst. to the Atty. Gen. (Sewall Key, Sp. Asst. to the Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and L. W. Creason, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before STONE and KENYON, Circuit Judges, and REEVES, District Judge.


KENYON, Circuit Judge.

This is a petition to review an order of the Board of Tax Appeals entered October 9, 1930, sustaining the assessment of an income tax deficiency against petitioner for the year 1922 to the amount of $2,333.45. Petitioner is engaged in the real estate business in Kansas City, Mo. A considerable portion of its income is derived from sales of real estate wherein the initial payment is less than 25 per cent. of the sale price. As permitted by article...

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