Allan L. Blair and Jocelyn Blair v. Commissioner of Internal Revenue

PELL, Circuit Judge.

In this appeal the petitioners contend that the United States Tax Court erroneously disallowed their income tax deduction for the year 1968 and determined a deficiency for that year. The facts of this litigation are set forth in detail in the Tax Court opinion, 63 T.C. 214 (1974), and the supplemental opinion of that court, 63 T.C. 744 (1975), and need not be similarly repeated here. There was no substantial dispute as to the dispositive facts which are as follows.

On July 14, 1965, the University of Illinois filed a petition in the state court for condemnation of a lot…