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HALLCRAFT HOMES, INC. v. C. I. R.

No. 18883.

336 F.2d 701 (1964)

HALLCRAFT HOMES, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

September 11, 1964.

Attorney(s) appearing for the Case

F. Edward Little, J. Keith McGregor, Los Angeles, Cal., for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., William A. Geoghegan, Asst. Deputy Atty. Gen., Lee A. Jackson, David O. Walter, Fred R. Becker, Dept. of Justice, Washington, D. C., for respondent.

Before ORR, BARNES and JERTBERG, Circuit Judges.

BARNES, Circuit Judge.

Petitioner petitions for a review of the decision of the Tax Court holding that a lump sum payment received by petitioner for the transfer of waterline refund agreements to the City of Phoenix was taxable as ordinary income rather than as capital gain. 40 T.C. 199. This court has jurisdiction of the petition pursuant to 26 U.S.C. § 7482 (§ 7482 of the Internal Revenue Code of 1954.) All references to...

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