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Watson v. Commissioner, 345 U.S. 544 (1953)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
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
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
Syllabus
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. 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. 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. 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. 553.
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Chicago: U.S. Supreme Court, "Syllabus," Watson v. Commissioner, 345 U.S. 544 (1953) in 345 U.S. 544 345 U.S. 545. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=6MJUD84M7JH2UE2.
MLA: U.S. Supreme Court. "Syllabus." Watson v. Commissioner, 345 U.S. 544 (1953), in 345 U.S. 544, page 345 U.S. 545. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=6MJUD84M7JH2UE2.
Harvard: U.S. Supreme Court, 'Syllabus' in Watson v. Commissioner, 345 U.S. 544 (1953). cited in 1953, 345 U.S. 544, pp.345 U.S. 545. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=6MJUD84M7JH2UE2.
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