S. H. Kress & Co. v. Commissioner
United States Tax Court
Sale of petitioner's store site to private garage operator under threat of condemnation, proceeds of which were invested in sites for other stores to be used by petitioner, held, on facts, an "involuntary conversion" under section 1033, I.R.C. 1954, entitling petitioner to non-recognition of gain.
1Opinion of the Court
S. H. Kress and Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
S. H. Kress & Co. v. Commissioner
Docket No. 86965
United States Tax Court
40 T.C. 142; 1963 U.S. Tax Ct. LEXIS 144;
April 25, 1963, Filed
Decision will be entered for the petitioner.
Sale of petitioner's store site to private garage operator under threat of condemnation, proceeds of which were invested in sites for other stores to be used by petitioner, held, on facts, an "involuntary conversion" under section 1033, I.R.C. 1954, entitling petitioner to non-recognition of gain.
A. Chauncey Newlin, Charles C.…
2Cases cited12 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Lynchburg Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1953
- Lynchburg Nat. Bank & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- City & County of San Francisco v. RossCalifornia Supreme Court · 1955
- Gaynor News Co. v. CommissionerUnited States Tax Court · 1954
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