Legal Opinion

Piedmont-Mt. Airy Guano Co. v. Commissioner

United States Board of Tax Appeals

Decided September 16, 1927No. Docket No. 8542PublishedCited by 4 opinions

1. Sale of property held not to be within the provisions of section 234(a)(14) of the Revenue Act of 1921. 2. March 1, 1913, value of land for purpose of computing gain or loss determined.

1Opinion of the Court

*74OPINION.

ARTJndell:

Section 234 (a) (14) of the Revenue Act of 1921, which is applicable to transactions under prior revenue acts, reads as follows:

If property is compulsorily or involuntarily converted into cash or its equivalent as a result of (A) its destruction in whole or in part, (B) theft or seizure, or (0) an exercise of the power of requisition or condemnation, or the threat or imminence thereof; and if the taxpayer proceeds forthwith in good faith, under regulations prescribed by the Commissioner with the approval of the Secretary, to expend the proceeds of such conversion in the…

2Cited by4 opinions

  1. Creative Solutions, Inc. (Formerly Alprodco, Inc.) v. United StatesCourt of Appeals for the Fifth Circuit · 1963
  2. Carson Estate Co. v. CommissionerUnited States Tax Court · 1963
  3. Dominguez Estate Co. v. CommissionerUnited States Tax Court · 1963
  4. Piedmont-Mt. Airy Guano Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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