GOTFREDSON v. COMMISSIONER OF INTERNAL REVENUE

No. 12134.

217 F.2d 673 (1954)

Robert B. GOTFREDSON and Charlotte B. Gotfredson, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

December 27, 1954.


Attorney(s) appearing for the Case

Thomas F. Chawke, Detroit, Mich. (Nathaniel W. Gold, Detroit, Mich., on the brief), for petitioners.

C. Guy Tadlock, Washington, D. C. (H. Brian Holland, Ellis N. Slack and Davis W. Morton, Jr., Washington, D. C., on the brief), for respondent.

Before McALLISTER, MILLER and STEWART, Circuit Judges.


MILLER, Circuit Judge.

The petitioners, who filed joint income tax returns, seek a review of rulings of the Tax Court adjudging deficiencies in income taxes for the years 1948 and 1949 in the amounts of $5,922.90 and $4,894.32 respectively. The issue presented is whether gain realized in the taxable years in question from the sale of dairy cattle held by the petitioners for six months or more constituted ordinary income or capital gain.

The principal facts...

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