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MANHATTAN BUILDING CO. v. COMMISSIONER

Docket No. 52460.

27 T.C. 1032 (1957)

THE MANHATTAN BUILDING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 29, 1957.

Attorney(s) appearing for the Case

Frank A. Harrington, Esq., and Donald M. Hawkins, Esq., for the petitioner.

Lyman G. Friedman, Esq., for the respondent.

OPINION.

TIETJENS, Judge:

The respondent determined deficiencies for 1945 in income tax in the amount of $30,473.03 and in personal holding company surtax in the amount of $3,207.21. The deficiencies resulted from the determination that the petitioner realized a long-term capital gain of $67,396.03 on the sale of certain real estate (referred to herein as the Summit Street property) instead of a loss of $32,603.97

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