Casalina Corp. v. Commissioner
United States Tax Court
Three tracts of land owned by petitioner, an accrual basis taxpayer, were condemned in the 1950's and the condemnor made deposits in the Federal District Court. During the course of the condemnation proceedings petitioner withdrew portions of these deposits in excess of its bases in the tracts. In 1967 and 1968 final judgments and interest thereon were awarded.
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Three tracts of land owned by petitioner, an accrual basis taxpayer, were condemned in the 1950's and the condemnor made deposits in the Federal District Court. During the course of the condemnation proceedings petitioner withdrew portions of these deposits in excess of its bases in the tracts. In 1967 and 1968 final judgments and interest thereon were awarded. Petitioner applied for nonrecognition of the gains on the awards under sec. 1033, I.R.C. 1954, representing that no gains were realized prior to the entry of these final judgments. Respondent initially approved petitioner's…
1Opinion of the Court
Casalina Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Casalina Corp. v. Commissioner
Docket No. 6158-70
United States Tax Court
60 T.C. 694; 1973 U.S. Tax Ct. LEXIS 81; 60 T.C. No. 73;
August 13, 1973, Filed
Decision will be entered under Rule 50.
Three tracts of land owned by petitioner, an accrual basis taxpayer, were condemned in the 1950's and the condemnor made deposits in the Federal District Court. During the course of the condemnation proceedings petitioner withdrew portions of these deposits in excess of its bases in the tracts. In 1967 and 1968 final judgments…
2Cases cited45 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- United States v. LewisSupreme Court of the United States · 1951
- Thrift v. CommissionerUnited States Tax Court · 1950
- MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
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