Legal Opinion

C. G. Willis, Inc. v. Commissioner

United States Tax Court

Decided January 13, 1964No. Docket No. 95319Published

Petitioner's self-propelled ship, Belvedere, was damaged and petitioner invested the insurance proceeds ($ 100,000) and proceeds from the sale of the damaged ship ($ 100,000 less commission) in a $ 270,000 barge. Held, the sale of the damaged ship (which was completely repairable) was not an involuntary conversion within the meaning of section 1033(a)(3)(A) and hence the gain on the sale of the ship in 1958 was taxable.

1Opinion of the Court

C. G. Willis, Incorporated, Petitioner, v. Commissioner of Internal Revenue, Respondent

C. G. Willis, Inc. v. Commissioner

Docket No. 95319

United States Tax Court

41 T.C. 468; 1964 U.S. Tax Ct. LEXIS 165;

January 13, 1964, Filed

Decision will be entered under Rule 50.

Petitioner's self-propelled ship, Belvedere, was damaged and petitioner invested the insurance proceeds ($ 100,000) and proceeds from the sale of the damaged ship ($ 100,000 less commission) in a $ 270,000 barge. Held, the sale of the damaged ship (which was completely repairable) was not an involuntary conversion within the meaning…

2Cases cited2 opinions

  1. C. G. Willis, Inc. v. CommissionerUnited States Tax Court · 1964
  2. S. E. Ponticos, Inc. v. CommissionerUnited States Tax Court · 1963

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