M. H. S. Company, Inc. v. Commissioner of Internal Revenue

This is an appeal from the decision of the United States Tax Court involving federal income tax deficiencies for the years ending September 30, 1966, 1967, 1969 and 1970 in the amounts of $19,444.52, $62.13, $996.50 and $977.16, respectively. Reference is made to the comprehensive findings of fact and opinion of Judge Irene F. Scott, reported at 35 T.C.M. 733 (1976), for a recitation of pertinent facts.

The taxpayer, a Tennessee corporation, was formed for the purpose of acquiring and leasing real estate. Certain of its real estate was acquired by the State of Tennessee by eminent domain,…