Brandon E. Jackson v. Artis Singleton, Warden

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• \Satisfying the 'held for sale to customers' requirement of section 1221(1) does not resolve the issue at hand. We must also determine whether [the taxpayer's] activities constituted a trade or business since the sale * * * must have been made in the ordinary course thereof.\
• subchapter S corporation which purchased tract of land, subdivided it, and then sold entire tract in a single transaction, was not in the business of selling land
• subchapter S corporation which purchased tract of land, subdivided it, and then sold entire tract in a single transaction, was not in the business of selling land
• involuntary sale of properties by taxpayer was not significant in determining whether taxpayer's transactions were frequent and substantial
• frequency of sales alone is not sufficient to establish a taxpayer is engaged in selling assets as a business
• “lack of frequent sales” is the most important factor for characterizing the taxpayer’s gain

Source: CourtListener parenthetical corpus (CC0).