CLINTON PARK DEVELOP. CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 14428.

209 F.2d 951 (1954)

CLINTON PARK DEVELOPMENT CO. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Fifth Circuit.

February 12, 1954.


Attorney(s) appearing for the Case

John E. Pledger, Jr., Houston Tex., John E. Pledger, Houston, Tex., of counsel, for petitioner.

Ellis N. Slack, Sp. Asst. to Atty. Gen., H. Brian Holland, Asst. Atty. Gen., Charles W. Davis, Chief Counsel, John M. Morawski, Sp. Atty., Bureau of Internal Revenue, Washington, D. C., Carolyn R. Just, Sp. Asst. to Atty. Gen., for respondent.

Before HUTCHESON, Chief Judge, and HOLMES and RIVES, Circuit Judges.


HOLMES, Circuit Judge.

The Clinton Park Development Company, a corporation, was organized to construct approximately 533 houses. The money necessary for the financing of this venture was obtained from loans guaranteed by the Federal Housing Administration, the financing expenses of which were paid by said company. During the year 1942, 507 of these houses were sold to purchasers under sales contracts, the terms of which required the purchasers to pay the F. H. A....

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