SEVIER TERRACE REALTY COMPANY v. C. I. R.

No. 15409.

327 F.2d 999 (1964)

SEVIER TERRACE REALTY COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

February 20, 1964.


Attorney(s) appearing for the Case

George D. Webster, Washington, D. C. (Davies, Richberg, Tydings, Landa & Duff, Washington, D. C., on the brief), for petitioner.

Robert A. Bernstein, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, L. W. Post, Stephen B. Wolfberg, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before WEICK, Chief Judge, and PHILLIPS, Circuit Judge, and McALLISTER, Senior Circuit Judge.


PER CURIAM.

This case involved questions concerning the taxpayer's basis of 303 acres of land known as Mount Ida Farm and located partly within and partly without the corporate limits of Kingsport, Tennessee. A further issue was presented as to whether the taxpayer in computing its income tax may deduct, as an ordinary and necessary business expense, the fair market value of 12 lots transferred to a social and recreation center to be used only by owners or residents...

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