Gaynor News Co. v. Commissioner
United States Tax Court
Petitioner acquired property, herein referred to as the "old property," intending promptly to erect thereon a plant suitable for its business. There were improvements on the property when acquired. An architect was employed who prepared plans for the new plant, and recommended clearing the land of existing improvements, which was done. Before construction work was begun upon the new plant, and while the land remained cleared, the City of Mt.
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Petitioner acquired property, herein referred to as the "old property," intending promptly to erect thereon a plant suitable for its business. There were improvements on the property when acquired. An architect was employed who prepared plans for the new plant, and recommended clearing the land of existing improvements, which was done. Before construction work was begun upon the new plant, and while the land remained cleared, the City of Mt. Vernon acquired the old property under its power of condemnation. Petitioner used the proceeds received from the City of Mt. Vernon to purchase all of…
1Opinion of the Court
OPINION.
Fisher, Judge:
The relevant provisions of the statute here involved are as follows:
SEC. 112. RECOGNITION OP GAIN OR LOSS.(f) Involuntary Conversion. — If property (as a result of * * * an exercise of the power of requisition or condemnation, or the threat or imminence thereof) is compulsorily or involuntarily converted into property similar or related in service or use to the property so converted, or into money which is forthwith in good faith, under regulations prescribed by the Commissioner with the approval of the Secretary, expended * * * in the acquisition of control of a…
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
- Massillon-Cleveland-Akron Sign Co. v. CommissionerUnited States Tax Court · 1950
3Cited by27 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
- Isenbergh v. CommissionerUnited States Tax Court · 1959
- John Richard Corp. v. CommissionerUnited States Tax Court · 1966
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