Land Sale Gain Deemed Ordinary Income!

A California District Court recently held that a taxpayer sustained ordinary income, not long term capital gain income, from a land sale because the underlying facts showed an intent to develop the property, as opposed to holding it for long term investment gain.

The decision (Frederic Allen v. U.S. (DC CA 5/28/14) 113 AFTR 2d) reminds us that conclusions in matters of…
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