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WATSON v. COMMISSIONER OF INTERNAL REVENUE

No. 12982.

197 F.2d 56 (1952)

WATSON et al. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Ninth Circuit.

May 29, 1952.

Attorney(s) appearing for the Case

A. Calder Mackay, Arthur McGregor, Howard W. Reynolds, Adam Y. Bennion, Richard N. Mackay, Charles J. Higson, Los Angeles, Cal., for petitioners.

Ellis N. Slack, Acting Asst. Atty. Gen., Hilbert P. Zarky, Irving Axelrad, Sp. Assts. to the Atty. Gen., for respondent.

Before DENMAN, Chief Judge, and STEPHENS and BONE, Circuit Judges.

DENMAN, Chief Judge.

This case is here on a petition to review a decision of the Tax Court, 15 T.C. 800, that the Commissioner of Internal Revenue was correct in assessing a deficiency against the taxpayer, Watson, in respect of personal income taxes for the year 1944. The issue for our determination is to what extent the profit from a sale of an orange grove, consisting of land, trees and an unmatured crop of oranges, should be apportioned...

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