MCCULLOUGH TRANSFER CO. v. COMMISSIONER

Docket No. 55209.

27 T.C. 822 (1957)

McCULLOUGH TRANSFER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 25, 1957.


Attorney(s) appearing for the Case

Donald J. Lynn, Esq., and S. J. Collins, C. P. A., for the petitioner.

Robert E. Johnson, Esq., for the respondent.


ATKINS, Judge:

The respondent determined deficiencies in income tax liability of the petitioner for the calendar years 1950 and 1951 in the respective amounts of $2,053.57 and $8,080.02. The question at issue under the pleadings is whether the gains derived by the petitioner upon the sale of certain trailers, trucks, and other motor vehicle equipment constituted ordinary income or capital gains.

FINDINGS OF FACT.

The petitioner is a corporation...

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