US LAWS, STATUTES and CODES : Chan Robles Virtual Law Library USA Supreme Court Decisions | Resolutions : Chan Robles Virtual Law Library

ChanRobles™ Virtual Law Library™ |™   
Main Index Repository of Laws, Statutes and Codes Latest Philippine Supreme Court Decisions Chan Robles Virtual Law Library Latest Legal Updates Philippine Legal Resources Significant Philippine Legal Resources Worldwide Legal Resources Philippine Supreme Court Decisions United States Legal Resources United States Supreme Court Jurisprudence ChanRobles LawTube - Social Network

ChanRobles Internet Bar Review : DebtKollect Company, Inc. - Debt Collection Firm Intellectual Property Division - Chan Robles Law Firm

Philippine Supreme Court DecisionsChanRobles On-Line Bar Review

google search for chanrobles.comSearch for

WATSON V. COMMISSIONER, 345 U. S. 544 (1953)

Subscribe to Cases that cite 345 U. S. 544 RSS feed for this section

U.S. Supreme Court

Watson v. Commissioner, 345 U.S. 544 (1953)

Watson v. Commissioner

No. 290

Argued February 2, 1953

Decided May 18, 1953

345 U.S. 544


For several years, a taxpayer held an undivided interest in an orange grove and engaged in the business of growing and selling the oranges it produced. In the midst of the 1944 growing season, she sold her interest in the grove, including an unmatured crop then on the trees.

Held: for federal income tax purposes, under § 117(j) of the Internal Revenue Code, as in effect in 1944, she must treat that part of her profit from the sale which is attributable to the unmatured crop as ordinary income -- not as a capital gain. Pp. 345 U. S. 545-553.

(a) It is immaterial that, under the law of the state where the land is situated, an unmatured, unharvested crop is treated as real property for many purposes. P. 345 U. S. 551.

(b) In the circumstances of this case, the proceeds of the sale fairly attributable to the crop were derived from property "held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business" within the meaning of § 117(j) as it existed in 1944. Pp. 345 U. S. 551-552.

197 F.2d 56 affirmed.

The Tax Court sustained a deficiency assessed by the Commissioner of Internal Revenue against petitioners, but reduced the amount. 15 T.C. 800. The Court of Appeals affirmed. 197 F.2d 56. This Court granted certiorari. 344 U.S. 895. Affirmed, p. 345 U. S. 553. chanroblesvirtualawlibrary

Page 345 U. S. 545

ChanRobles™ LawTube

google search for Search for

Supreme Court Decisions Philippine Supreme Court DecisionsUS Supreme Court Decisions



Browse By ->> Volume


Browse By ->> Year


  Copyright © ChanRobles Publishing Company | Disclaimer | E-mail Restrictions
ChanRobles™ Virtual Law Library |™