Raymond Saltzman v. Commissioner of Internal Revenue

Third Circuit

Raymond Saltzman v. Commissioner of Internal Revenue

227 F.2d 49

Court of Appeals for the Third Circuit·Decided November 1, 1955·No. 11616_1·Published·Cited by 2 cases

Opinion

PER CURIAM.

From our own examination we think the Tax Court’s conclusion that the properties in question were held by petitioner primarily for sale to customers in the ordinary course of his trade or business within the meaning of Section 117(a) and (j) of the Internal Revenue Code of 1939, as amended, 26 U.S.C.A. § 117(a, j), is fully justified by the record.

The decision of the Tax Court will be affirmed.

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PER CURIAM.

From our own examination we think the Tax Court’s conclusion that the properties in question were held by petitioner primarily for sale to customers in the ordinary course of his trade or business within the meaning of Section 117(a) and (j) of the Internal Revenue Code of 1939, as amended, 26 U.S.C.A. § 117(a, j), is fully justified by the record.

The decision of the Tax Court will be affirmed.

Raymond Saltzman v. Commissioner of Internal Revenue, 227 F.2d 49 (3d Cir. 1955).

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Opinion

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