Legal Opinion
Steuart Brothers, Inc., a Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided December 17, 1958No. 7669PublishedCited by 23 opinions
1Opinion of the Court
SOPER, Circuit Judge.
This petition for review presents the contention of the taxpayer that under § 112 of the Internal Revenue Code of 1939, 26 U.S.C.A. § 112, no taxable gain was involved in a condemnation award of $425,000 from the United States whereby the taxpayer realized a gain of $349,-058.54. The statute provided:
“§ 112. Recognition of Gain or Loss.— * * *
“(f) Involuntary Conversion. If property (as a result of its destruction in whole or in part, theft, seizure, or requisition or condemnation or threat or imminence thereof) is compulsorily or involuntarily converted—
“(1) Conversion…
2Cases cited11 opinions
- 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
- Kimbell-Diamond Milling Co. v. CommissionerUnited States Tax Court · 1948
- Haberland v. CommissionerUnited States Board of Tax Appeals · 1932
- Gaynor News Co. v. CommissionerUnited States Tax Court · 1954
6 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Lucile McAulay Filippini, as of the Last Will and Testament of Carra McAulay Deceased v. United StatesCourt of Appeals for the Ninth Circuit · 1963
- 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
- Thomas McCaffrey Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
- Liant Record, Inc. v. CommissionerUnited States Tax Court · 1961
18 more not listed; retrieve them via the Exa API.