PENNROAD CORPORATION AND AFFILIATED COMPANIES v. COMMISSIONER

Docket Nos. 58979, 64889.

29 T.C. 914 (1958)

THE PENNROAD CORPORATION AND AFFILIATED COMPANIES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 20, 1958.


Attorney(s) appearing for the Case

Charles S. Jacobs, Esq., William R. Spofford, Esq., and Charles I. Thompson, Jr., Esq., for the petitioner.

George H. Bowers, Jr., Esq., for the respondent.


The respondent determined deficiencies in income tax against the petitioner for the years 1950, 1951, and 1952 of $11,224.33, $69,677.64, and $80,219.88. The only question for decision is whether gains realized on the sale of real estate during the years herein are taxable as long-term capital gains, or as ordinary income. One issue involving the disallowance of a claimed interest deduction has been conceded by petitioner.

FINDINGS OF FACT.

Some of the facts...

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