United States Board of Tax Appeals August 15, 1941, Docket No. 100486. (Frost Lumber Industries, Inc. v. Commissioner)

lead-opinion

*1252OPINION.

Murdock:

The petitioner has devoted its brief to the law of real estate contracts in Louisiana. It argues that an irrevocable, binding contract for the sale of land resulted when the Government notified the petitioner on August 23, 1935, of the election to purchase undei the option; ownership passed at that time; title passed when the deed was executed and recorded in