The taxpayer, which was engaged in dealing in scrap metals, smelting and refining non-ferrous metals, and in carrying on a wrecking and salvage operation and a steel fabrication and erection operation received $78,096 over book for the inventory of its non-ferrous division on the sale of all the assets (including goodwill) of the non-ferrous operation.
Because the non-ferrous operation was a separate business, the above profit of $78,096 was received on capital account. The sale of the inventory "was not a sale in the business of the appellant, but was made as a part of a sale of a business of the appellant."