United States Tax Court January 31, 1972, Docket Nos. 1538-70, 1546-70, 1596-70, 1597-70 (Howell v. Commissioner)

Steeeett, Judge:

Respondent determined deficiencies in petitioners’ income taxes for the years and in the amounts as follows:

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The issues for decision are:

(1) Whether certain real property, which constituted the only property held by Hectare, Inc., and was sold by it during 1964, 1965, and 1966, was a capital asset within the meaning of section 1221,I.R.C.