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HELEN JANE MARTINA SCHWERIN TRUST v. COMMISSIONER

Docket No. 42619.

13 T.C.M. 202 (1954)

Helen Jane Martina Schwerin Trust, Solana Land Company, Trustee v. Commissioner.

United States Tax Court.

Entered March 11, 1954.

Attorney(s) appearing for the Case

Carl A. Stutsman, Jr., Esq., 411 West Fifth Street, Los Angeles, Calif., and John M. Schwartz, Esq., for the petitioner. John J. Burke, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HARRON, Judge:

The Commissioner has determined a deficiency in income tax for the year 1946 in the amount of $26,872.35. The question to be decided is whether pieces of real estate, 16 lots in a subdivision, and 80 acres of unimproved land, sold by the petitioner in 1946 at a profit of $75,896.80, were held by the petitioner primarily for sale to customers in the ordinary...

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