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HOLLYWOOD BASEBALL ASSOCIATION v. COMMISSIONER

Docket No. 93647.

42 T.C. 234 (1964)

HOLLYWOOD BASEBALL ASSOCIATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 21, 1964.

Attorney(s) appearing for the Case

Arthur E. Gore, for the petitioner.

Douglas W. Argue and Lawrence S. Kartiganer, for the respondent.

FORRESTER, Judge:

Respondent has determined deficiencies of $25,502.07, $20,004.38, and $8,760.08 for the taxable years ending October 31, 1955, October 31, 1956, and October 31, 1958,1 respectively. The three remaining issues before us are as follows:

(1) Whether gain realized from the sale of certain baseball player contracts is within the purview of section 337;

(2) Whether an amount realized pursuant to the transfer...

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