S. E. Ponticos, Inc. v. Commissioner
United States Tax Court
Petitioner sold a building, which was rented to commercial tenants as a warehouse and place of business, to the City of Cincinnati, Ohio, under threat of condemnation. The proceeds of such sale were reinvested in a garden-type apartment development.
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Petitioner sold a building, which was rented to commercial tenants as a warehouse and place of business, to the City of Cincinnati, Ohio, under threat of condemnation. The proceeds of such sale were reinvested in a garden-type apartment development. Held, that the property purchased did not constitute "property similar or related in service or use to the property so converted," within the meaning of section 1033(a)(3)(A), I.R.C. 1954, and that the petitioner is therefore not entitled to nonrecognition of gain upon the disposition of the converted building.
1Opinion of the Court
S. E. Ponticos, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
S. E. Ponticos, Inc. v. Commissioner
Docket No. 84692
United States Tax Court
40 T.C. 60; 1963 U.S. Tax Ct. LEXIS 150;
April 18, 1963, Filed
Decision will be entered for the respondent.
Petitioner sold a building, which was rented to commercial tenants as a warehouse and place of business, to the City of Cincinnati, Ohio, under threat of condemnation. The proceeds of such sale were reinvested in a garden-type apartment development. Held, that the property purchased did not constitute "property similar or related in…
Also in this document: Dissent.
2Cases cited13 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
- Steuart Brothers, Inc., a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1958
- Thomas McCaffrey Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
- Liant Record, Inc. v. CommissionerUnited States Tax Court · 1961
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