Legal Opinion

Conlorez Corp. v. Commissioner

United States Tax Court

Decided December 24, 1968No. Docket No. 6746-66Published

New York State appropriated certain property of the petitioner in 1959. A partial payment of $ 81,900 in respect of such property was made to the petitioner in 1961, and the New York Court of Claims awarded the petitioner $ 166,575 in 1964. The petitioner's adjusted basis in the property was less than $ 81,900. The petitioner replaced the property in 1965 with other property similar or related in service or use.

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New York State appropriated certain property of the petitioner in 1959. A partial payment of $ 81,900 in respect of such property was made to the petitioner in 1961, and the New York Court of Claims awarded the petitioner $ 166,575 in 1964. The petitioner's adjusted basis in the property was less than $ 81,900. The petitioner replaced the property in 1965 with other property similar or related in service or use. Held: 1. The petitioner realized gain in 1961 as the result of the partial payment. Accordingly, it may not elect sec. 1033 nonrecognition treatment of its gain on the appropriated…

1Opinion of the Court

Conlorez Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Conlorez Corp. v. Commissioner

Docket No. 6746-66

United States Tax Court

51 T.C. 467; 1968 U.S. Tax Ct. LEXIS 6;

December 24, 1968, Filed

Decision will be entered under Rule 50.

New York State appropriated certain property of the petitioner in 1959. A partial payment of $ 81,900 in respect of such property was made to the petitioner in 1961, and the New York Court of Claims awarded the petitioner $ 166,575 in 1964. The petitioner's adjusted basis in the property was less than $ 81,900. The petitioner replaced the…

2Cases cited23 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Conlorez Corp. v. CommissionerUnited States Tax Court · 1968
  3. Ferguson v. CommissionerUnited States Tax Court · 1950
  4. Bebb v. CommissionerUnited States Tax Court · 1961
  5. Crude Oil Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1947

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