Legal Opinion

Ft. Hamilton Manors, Inc. v. Commissioner

United States Tax Court

Decided February 4, 1969No. Docket Nos. 2709-65, 2710-65Published

1. Held, that the petitioners did not, within the period specified in sec. 1033, I.R.C. 1954, purchase properties to replace properties converted as a result of condemnation, and that therefore the gains upon the conversions are not entitled to the nonrecognition-of-gain provisions of that section. 2. A reasonable allowance for compensation of the petitioners' officers determined.

1Opinion of the Court

Fort Hamilton Manor, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Dayton Development Fort Hamilton Corp., Petitioner v. Commissioner of Internal Revenue, Respondent

Ft. Hamilton Manors, Inc. v. Commissioner

Docket Nos. 2709-65, 2710-65

United States Tax Court

51 T.C. 707; 1969 U.S. Tax Ct. LEXIS 198;

February 4, 1969, Filed

Decisions will be entered under Rule 50.

1. Held, that the petitioners did not, within the period specified in sec. 1033, I.R.C. 1954, purchase properties to replace properties converted as a result of condemnation, and that therefore the gains upon the…

2Cases cited18 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  3. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  4. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  5. United States v. LewisSupreme Court of the United States · 1951

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