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MILLS v. COMMISSIONER

Docket No. 4426-70.

59 T.C. 401 (1972)

CABAX MILLS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 13, 1972.

Attorney(s) appearing for the Case

Milo E. Ormseth and Thomas B. Stoel, for the petitioner.

Lee A. Kamp, for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency in petitioner's corporate income tax in the amount of $49,648.84 for its calendar year ended December 31, 1965. The issue presented for our decision is whether for purposes of section 631(a) of the Internal Revenue Code,1 petitioner held certain timber-cutting contracts, which it received in a liquidation distribution, for more than 6 months prior to January 1, 1965.

FINDINGS...

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