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NATIONAL ICE AND COLD STORAGE COMPANY OF CALIFORNIA v. COMMISSIONER

Docket No. 7318.

6 T.C.M. 80 (1947)

National Ice and Cold Storage Company of California v. Commissioner.

United States Tax Court.

Entered January 31, 1947.

Attorney(s) appearing for the Case

Valentine Brookes, Esq., and Arthur H. Kent, Esq., 1720 Mills Tower, San Francisco 4, Calif., for the petitioner. W. J. McFarland, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $19,762.18 in the income tax of the petitioner for the calendar year 1940. The issues for decision are:

(1) whether the petitioner's basis for loss on four mountain properties was $120,193.62 or a much smaller amount;

(2) whether the petitioner realized income of $100,800 from a transaction in which it, inter alia,...

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