ROUSE v. COMMISSIONER

Docket No. 83294.

39 T.C. 70 (1962)

RANDOLPH D. ROUSE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 10, 1962.


Attorney(s) appearing for the Case

Fred R. Tansill, Esq., and Louis Hoppe, Esq., for the petitioner.

W. Ralph Musgrove, Esq., for the respondent.


This proceeding involves deficiencies in petitioner's income tax for 1953, 1954, and 1955 in the respective amounts of $58,721.95, $48,099.17, and $35,257.63. The questions in issue are: (1) Whether the gains from the sale of houses which petitioner purchased at cost from construction companies in which he owned a controlling interest and which he held for rent for periods of 6 months or longer are taxable as long-term capital gains or as ordinary income, and (2) whether...

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