WESTCHESTER DEVELOPMENT CO. v. COMMISSIONER

Docket No. 6315-72.

63 T.C. 198 (1974)

WESTCHESTER DEVELOPMENT COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 14, 1974.


Attorney(s) appearing for the Case

Robert L. Waters, for the petitioner.

Daniel A. Taylor, Jr., for the respondent.


FAY, Judge:

Respondent has determined deficiencies in the Federal income taxes of petitioner in the amounts of $47,224.77 and $311,871.79 for fiscal years ended February 29, 1968, and February 28, 1969, respectively.

The issues to be decided are:

(1) Whether the gain recognized by the petitioner on sales of real estate other than single-family dwelling sites was capital gain or ordinary income;

(2) Whether the additions which petitioner...

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