Suburban Realty Company v. United States

How courts have described this case

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

• rejecting the notion that “all gains emanating from appreciation in value over a substantial period of time are to be treated as capital gains”
• “[T]he question of taxpayer’s purpose or purposes for holding the property is primarily factual, as is the question of which purpose predominates.”
• “[T]he presence of frequent sales ordinarily belies the contention that property is being held ‘for investment’ rather than ‘for sale.’”
• taxpayer made 244 sales over a thirty-two year period

Source: CourtListener parenthetical corpus (CC0).