AUSTIN v. COMMISSIONER

Docket No. 57111.

17 T.C.M. 346 (1958)

T.C. Memo. 1958-71

Robert E. Austin and Marian H. Austin v. Commissioner.

United States Tax Court.

Filed April 24, 1958.


Attorney(s) appearing for the Case

Wendell H. Davis, Esq., and Robert E. Austin, Esq., pro se, 500 Poinsettia Avenue, Manhattan Beach, Calif., for petitioners. Gene F. Reardon, Esq., for respondent.


Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in petitioners' income tax for the years 1950, 1951 and 1952 in the respective amounts of $395.96, $429.46 and $1,676.88.

At issue is whether lots which were the subject of certain sales were held by petitioners primarily for sale to customers in the ordinary course of their trade or business.

Findings of Fact

Some of the facts have been stipulated and are so found...

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