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GORDY v. COMMISSIONER

Docket No. 82044.

36 T.C. 855 (1961)

RALPH E. GORDY AND KATHERINE F. GORDY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 17, 1961.

Attorney(s) appearing for the Case

James J. Convery, Esq., for the petitioners.

Stephen P. Cadden, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined deficiencies in petitioners' income tax for the years 1953 through 1956, as follows: 1953, $1,651.22; 1954, $2,652.88; 1955, $1,829.08; and 1956, $6,228.45. The questions for decision are whether amounts received from the sale of an option to purchase land and whether an amount received from the sale of an interest in an undeveloped tract of land are taxable as ordinary income or as capital gain.

FINDINGS...

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