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COMMISSIONER OF INTERNAL REVENUE v. BOCA CEIGA DEVELOPMENT CO.

No. 5082.

66 F.2d 1004 (1933)

COMMISSIONER OF INTERNAL REVENUE v. BOCA CEIGA DEVELOPMENT CO.

Circuit Court of Appeals, Third Circuit.

August 23, 1933.

Attorney(s) appearing for the Case

Sewall Key and John G. Remey, Sp. Assts. to Atty. Gen. (C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and James K. Polk, Jr., Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., of counsel), for petitioner.

Palmer Watson, of Philadelphia, Pa., for respondent.

Before BUFFINGTON, DAVIS, and THOMPSON, Circuit Judges.

DAVIS, Circuit Judge.

This petition involves income taxes for the fiscal year ending February 28, 1926.

On October 30, 1925, the respondent, the Boca Ceiga Development Company, a Florida real estate corporation, sold a tract of land to one of its stockholders for a gross consideration of $504,000, and received from the purchaser 480 shares of its capital stock, valued at $48,000, as the initial payment. For income...

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