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TRIPLE E DEVELOPMENT COMPANY v. COMMISSIONER

Docket No. 26008.

20 T.C. 619 (1953)

TRIPLE E DEVELOPMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 17, 1953.

Attorney(s) appearing for the Case

Chester H. Ferguson, Esq., George V. Ericksen, Esq., and Rex Meighen, C. P. A., for the petitioner.

Newman A. Townsend, Jr., Esq., for the respondent.

OPINION.

TURNER, Judge:

The respondent determined deficiencies in income tax and excess profits tax against the petitioner for the fiscal year ending August 31, 1946, in the respective amounts of $133,489.49 and $72,758.68. The only issue for determination is whether the petitioner may treat part of the purchase prices of citrus groves having growing crops thereon as cost of fruit sold, in arriving at the gain realized from subsequent sales of the...

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