Legal Opinion

Forest City Chevrolet v. Commissioner

United States Tax Court

Decided June 15, 1977No. Docket No. 6305-73Unpublished

Held, petitioner sold only a portion of its property under "threat or imminence" of condemnation, pursuant to sec. 1033, I.R.C. 1954. Other portions of its property were not sold under "threat or imminence" of condemnation.

1Opinion of the Court

FOREST CITY CHEVROLET, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Forest City Chevrolet v. Commissioner

Docket No. 6305-73.

United States Tax Court

T.C. Memo 1977-187; 1977 Tax Ct. Memo LEXIS 254; 36 T.C.M. (CCH) 768; T.C.M. (RIA) 770187;

June 15, 1977, Filed

Held, petitioner sold only a portion of its property under "threat or imminence" of condemnation, pursuant to sec. 1033, I.R.C. 1954. Other portions of its property were not sold under "threat or imminence" of condemnation.

Burton L. Williams, for the petitioner.

Justin S. Holden, for the respondent.

WILES

MEMORANDUM FINDINGS OF…

2Cases cited5 opinions

  1. Masser v. CommissionerUnited States Tax Court · 1958
  2. Rainier Cos. v. CommissionerUnited States Tax Court · 1973
  3. Warner v. CommissionerUnited States Tax Court · 1971
  4. Smith v. CommissionerUnited States Tax Court · 1971
  5. Rainier Companies, Inc. v. C. I. RCourt of Appeals for the Ninth Circuit · 1975

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