The chief source of income of the taxpayer from farm land which she held in Scarborough was the sale in most of the years from 1945 to 1952 of topsoil to a company controlled by her husband, which then removed the topsoil at its expense. In 1953, the taxpayer sold the portion of the lands from which she had been removing topsoil, obtained the covenant of the purchaser to remove the topsoil from the purchased lands and deposit them on the remaining lands held by her, and then sold that topsoil to her husband's company for a lump sum.
All the sums received by her for the sale of topsoil were ordinary income.