Rainier Cos. v. Commissioner
United States Tax Court
In 1964 petitioner decided that it wanted to sell its baseball stadium which it had owned since 1938. Although the stadium site had potential as a shopping center development, petitioner felt that the best way of disposing of the stadium was to sell it to the public.
Read the full summary
In 1964 petitioner decided that it wanted to sell its baseball stadium which it had owned since 1938. Although the stadium site had potential as a shopping center development, petitioner felt that the best way of disposing of the stadium was to sell it to the public. From the time of petitioner's initial offer to the middle of 1965, the response of public officials was not enthusiastic or encouraging; however, in July 1965 city officials decided that they could acquire the stadium as an advanced right-of-way acquisition for a proposed expressway. Although construction of the expressway was…
1Opinion of the Court
Ihwin, Judge:
Respondent determined deficiencies of $270,262 and $34,564 in the income taxes of petitioner for the years 1966 and 1967, respectively. After concessions by the parties three issues remain for decision: (1) Whether petitioner’s sale of its baseball stadium site to the City of Seattle was an involuntary conversion under threat of condemnation entitling petitioner to defer recognition of the gain under section 1033;1 (2) whether petitioner’s alleged donation of stadium improvements to the City of Seattle constitutes a charitable contribution under section 170; and (3) whether…
2Cases cited6 opinions
- Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Sutton v. CommissionerUnited States Tax Court · 1971
- Grinslade v. CommissionerUnited States Tax Court · 1973
- Maixner v. CommissionerUnited States Tax Court · 1959
- S. & B. Realty Co. v. CommissionerUnited States Tax Court · 1970
1 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Louisville & N. R. Co. v. CommissionerUnited States Tax Court · 1976
- Rusoff v. CommissionerUnited States Tax Court · 1975
- Tecumseh Corrugated Box Co. v. CommissionerUnited States Tax Court · 1990
- Tecumseh Corrugated Box Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
10 more not listed; retrieve them via the Exa API.