PACIFIC HOMES v. UNITED STATES

No. 14732.

230 F.2d 755 (1956)

PACIFIC HOMES, Inc., a Corporation, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Ninth Circuit.

February 21, 1956.


Attorney(s) appearing for the Case

L. W. Wrixon, Carl R. Schulz, San Francisco, Cal., for appellant.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, C. Guy Tadlock, Sp. Assts. to Atty. Gen., Lloyd H. Burke, U. S. Atty., San Francisco, Cal., for appellee.

Before DENMAN, Chief Judge, and LEMMON and CHAMBERS, Circuit Judges.


LEMMON, Circuit Judge.

The sovereign is not to be frustrated in the replenishment of its fisc by the fine-spun arguments advanced by the appellant. When the taxpayer itself, in its income tax returns, has repeatedly described its business as that of renting and selling homes; when it has developed a crafty technique whereby it can quicken its sales; when, in three other tracts, not here in issue, the appellant sold all its houses; when its board...

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