BURNS v. COMMISSIONER

Docket No. 25314.

14 T.C.M. 544 (1955)

T.C. Memo. 1955-147

Jay Burns v. Commissioner.

United States Tax Court.

Filed June 13, 1955.


Attorney(s) appearing for the Case

Alex P. Gaines, Esq., and John E. Simpson, Esq., for the petitioner. Thomas C. Cravens, Jr., Esq., for the respondent.


Supplemental Memorandum Findings Fact and Opinion

TURNER, Judge:

This proceeding was remanded by the United States Court of Appeals for the Fifth Circuit [55-1 USTC ¶ 9198], on the question whether certain lots located near Tampa, Florida, and sold by petitioner in 1947 were property used in the trade or business of the petitioner within the meaning of section 117(a) of the Internal Revenue Code of 1939, and...

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