Ft. Hamilton Manors, Inc. v. Commissioner
United States Tax Court
1. Held, that the petitioners did not, within the period specified in sec. 1033, I.R.C. 1954, purchase properties to replace properties converted as a result of condemnation, and that therefore the gains upon the conversions are not entitled to the nonrecognition-of-gain provisions of that section. 2. A reasonable allowance for compensation of the petitioners' officers determined.
1Opinion of the Court
Atkins, Judge:
The respondent determined income tax deficiencies against the petitioner Fort Hamilton Manor, Inc., for the taxable years ended May 31, 1961 and 1962, in the respective amounts of $362,058 and $12,705 and against the petitioner Dayton Development Fort Hamilton Corp. for the taxable year ended November 30, 1961, in the amount of $158,659.
The issues are (1) whether under section 1033 of the Internal Revenue Code of 1954, gains realized by the petitioners in their taxable years ended May 31 and November 30,1961, upon the taking of their property by the United States under…
2Cases cited17 opinions
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