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FRANK H. TAYLOR & SON, INC. v. COMMISSIONER

Docket No. 599-71.

32 T.C.M. 362 (1973)

T.C. Memo. 1973-82

Frank H. Taylor & Son, Inc., note first name v. Commissioner.

United States Tax Court.

Filed April 10, 1973.

Attorney(s) appearing for the Case

Bradford P. Colcord and Robert C. Harrison, 30 Rockefeller Plaza, New York, N.Y. for the petitioner. Timothy L. Nelson, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent has determined a deficiency of $9,200 in petitioner's income tax for 1966. The sole issue is whether certain unimproved real estate, which petitioner sold at a gain in 1966, was held primarily for sale to customers in the ordinary course of petitioner's business within the meaning of section 1221(1).1

Findings of Fact

Petitioner is a New...

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