Buffalo Wire Works Co. v. Comm'r
United States Tax Court
The city of Buffalo condemned petitioner's land, building, and fixtures. Under New York law, the award that petitioner would receive for the fixtures was determined as the lesser of: (1) The difference between present value in place and salvage value; and (2) the costs of disassembling, trucking, and reassembling the fixtures. The latter was used to value the fixtures.
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The city of Buffalo condemned petitioner's land, building, and fixtures. Under New York law, the award that petitioner would receive for the fixtures was determined as the lesser of: (1) The difference between present value in place and salvage value; and (2) the costs of disassembling, trucking, and reassembling the fixtures. The latter was used to value the fixtures. Petitioner treated the entire condemnation award, which was received in 1972, as an amount realized upon the involuntary conversion of property into money under sec. 1033, I.R.C. 1954. Petitioner purchased qualified replacement…
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioner as follows:
Taxable year Deficiency in tax
1969 . $2,317
1970 . 2,317
1971 . 5,792
1972 . 187,345
Five issues are presented for our decision:(1) Whether $418,052 was includable in the income of petitioner for the taxable year 1972 as ordinary income from the reimbursement of moving expenses;(2) Whether $12,110 was includable in the income of petitioner for the taxable year 1972 as ordinary income from the excess reimbursement of moving expenses;(3) Whether the moving expenses of petitioner for the…
2Cases cited12 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Union Planters National Bank of Memphis v. United StatesCourt of Appeals for the Sixth Circuit · 1970
- Golsen v. CommissionerUnited States Tax Court · 1970
- Louis Spitalny and Betty Spitalny, His Wife v. United States of America, William Erdwurm and Bart F. Erdwurm, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Harvey Textile Co. v. HillSupreme Court of Connecticut · 1949
7 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Tiefenbrunn v. CommissionerUnited States Tax Court · 1980
- Maines v. Comm'rUnited States Tax Court · 2015
- Buffalo Wire Works Co. v. Comm'rUnited States Tax Court · 1980
- David J. Maines & Tami L. Maines v. CommissionerUnited States Tax Court · 2015
- Maines v. Comm'rUnited States Tax Court · 2015
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