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DILLON v. COMMISSIONER

Docket No. 34470.

12 T.C.M. 338 (1953)

Robert W. Dillon v. Commissioner.

United States Tax Court.

March 30, 1953.

Attorney(s) appearing for the Case

Robert Ash, Esq., 550 Munsey Building, Washington, D. C., and Carl F. Bauersfeld, Esq., for the petitioner. Marvin E. Hagen, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

WITHEY, Judge:

The respondent determined a deficiency of $26,801.09 in the income tax liability of the petitioner for the calendar year 1946.

The issue is whether or not a gain realized on the sale of 20 houses in the taxable year is taxable as ordinary income or as long-term capital gain. Petitioner's 1946 Federal income tax return reported the sale of 33 houses...

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