ITG FAQ #10 answer - Is income from the operation of a motel or a smoke shop on allotted land taxable?

Income from the operation of a motel or a smoke shop on allotted land has been held to derive from labor and the use of capital improvements rather than directly from the land itself and has accordingly been held taxable. (Critzer v. United States, 597 F.2d 708 (Ct.Cl.) cert denied).

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