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SPROUL REALTY CO. v. COMMISSIONER

Docket No. 90563.

38 T.C. 844 (1962)

SPROUL REALTY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 13, 1962.

Attorney(s) appearing for the Case

Fred L. Rosenbloom, Esq., for the petitioner.

Edward L. Newberger, Esq., for the respondent.

The Commissioner determined a deficiency in petitioner's income tax for the fiscal period July 1 to September 25, 1957, in the amount of $87,717.68. At issue is the applicability of the nonrecognition provisions of section 337(a) of the 1954 Code to petitioner's sale of certain corporate property pursuant to a plan of complete liquidation. The Commissioner has determined that the nonrecognition provisions do not apply based on the limitation in section 337(c) excluding collapsible...

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