Court of Appeals for the Ninth Circuit June 28, 1955, 14374 (S. Nicholas Jacobs and Dolores I. Jacobs v. Commissioner of Internal Revenue)

DENMAN, Chief Judge.

Petitioners, husband and wife filing joint returns, seek a review of the Tax Court’s findings,and decision of the income tax liability of petitioners for the year 1948. Since all the pertinent transactions were by 'the husband he is hereafter called petitioner.

The Tax Court found that at all pertinent times petitioner was in the business of holding and selling land.