CARSON ESTATE COMPANY v. COMMISSIONER

Docket No. 92299.

22 T.C.M. 425 (1963)

T.C. Memo. 1963-90

Carson Estate Company v. Commissioner.

United States Tax Court.

Filed March 28, 1963.


Attorney(s) appearing for the Case

A. Calder Mackay, Esq., 523 W. 6th St., Los Angeles, Calif., and Adam Y. Bennion, Esq., for the petitioner. Robert L. Gnaizda, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

A deficiency of $13,479.60 in petitioner's income tax for the year 1957, all of which is in dispute, has been determined by the respondent. The question for decision is whether certain real property was sold by the petitioner to the County of Los Angeles, California, under threat or imminence of condemnation so that it qualified as an involuntary conversion under section 1033 of the Internal Revenue...

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