GRIMALDI v. COMMISSIONER

Docket No. 91016.

22 T.C.M. 739 (1963)

T.C. Memo. 1963-156

William S. Grimaldi and Elizabeth S. Grimaldi v. Commissioner.

United States Tax Court.

Filed June 6, 1963.


Attorney(s) appearing for the Case

Harold Kamens, 10 Commerce Court, Newark, N. J., for the petitioners. Gerald N. Daffner, for the respondent.


Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the years 1954, 1955, and 1956 in the amounts of $4,603.04, $3,225.77, and $1,162.83, respectively. The issues to be decided are:

(1) Whether vacant and improved property and interests in property sold by petitioners during the years in issue were at the time of sale held by petitioners primarily for sale to customers in the ordinary...

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