Pierce Butler

“ January 5, 1917, the papers which were required to effect the transfer were delivered, the purchase price was paid, and the transaction was finally closed.
Respondent kept its accounts on the accrual basis, and treated the profits derived from the sale as income in 1916. The Commissioner of Internal Revenue determined that the gain had been realized in, and was taxable for, 1917. The Board of Tax Appeals sustained his finding. 7 B. T. A. 1193. The Circuit Court of Appeals reversed the Board. 30 F. (2d) 680.
The gain derived from this sale was taxable income. ”

“ On the same day title was examined and found satisfactory to the Pine Company. It arranged for the money needed, and December 30, 1916, notified respondent that it would exercise the option, On that day respondent ceased operations and withdrew all employees from the land. ”