Rev. Rul. 57-90, 1957-1 CB 199

REV-RUL, SECTION 631.--GAIN OR LOSS IN THE CASE OF TIMBER OR COAL, Rev. Rul. 57-90, 1957-1 CB 199, (Jan.01, 1957)

SECTION 631.--GAIN OR LOSS IN THE CASE OF TIMBER OR COAL
(Also Section 1231)

In the case of the disposal of timber, held for more than six months prior to such disposal, by the owner thereof under any form or type of contract by virtue of which the owner retains an economic interest in such timber, pursuant to the provisions of section 631(b) of the Internal Revenue Code of 1954, the gain or loss on such disposal is subject to the tax treatment provided by section 1231 regardless of the nature of the taxpayer's business or the purpose for which the timber is held. To the extent that the opinion in Ah Pah Redwood Co., v. Commissioner, 26 T. C. 1197, maybe inconsistent with the foregoing, it does not represent the position of the Internal Revenue Service.