McCaffrey v. Commissioner
United States Tax Court
Petitioner's real property, which was situated in a downtown industrial section of Pittsburgh, Pennsylvania, and which at the time of acquisition as well as during the petitioner's ownership was leased for, and was used for, parking purposes, was "involuntarily converted" into cash through condemnation proceedings.
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Petitioner's real property, which was situated in a downtown industrial section of Pittsburgh, Pennsylvania, and which at the time of acquisition as well as during the petitioner's ownership was leased for, and was used for, parking purposes, was "involuntarily converted" into cash through condemnation proceedings. The petitioner used the proceeds of the conversion to purchase stock in an acquisition of control of a corporation which owned real property situated in the industrial section of New Castle, Pennsylvania, and which the corporation leased to the Federal Civil Defense Administration…
1Opinion of the Court
Withey, Judge:
The respondent determined a deficiency of $11,-082.10 in the income tax of the petitioners for 1953. The only issue presented for decision is whether the petitioners are entitled to the nonrecognition of gain exemption provided for in section 112 (f) of the Internal Revenue Code of 1939, with respect to a transaction wherein real property used for a parking lot was taken by condemnation proceedings by the Commonwealth of Pennsylvania and the proceeds received by petitioner Thomas McCaffrey, Jr., from the condemnation proceedings were used by him to purchase stock in the…
2Cases cited3 opinions
- 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
- Steuart Bros., Inc. v. CommissionerUnited States Tax Court · 1957
3Cited by16 opinions
- Loco Realty Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Liant Record, Inc., William I. Alpert and Paula G. Alpert, Abraham Alpert and Sarah Alpert, Jack L. Alpert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Liant Record, Inc. v. CommissionerUnited States Tax Court · 1961
- Filippini v. United StatesDistrict Court, N.D. California · 1961
- Johnson v. CommissionerUnited States Tax Court · 1965
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