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This document is a court opinion regarding whether a taxpayer can treat the gain from selling a partially completed apartment building as a long-term capital gain under Section 117(j) of the Internal Revenue Code. The court held that the portion of the gain properly allocable to the part of the building erected more than six months before the sale could be treated as a long-term capital gain, but not the entire gain. The court rejected arguments that the holding period began when the taxpayer became contrac

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Scribd Government Docs

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