RIDGEWOOD LAND COMPANY, INC. v. COMMISSIONER

Docket No. 4934-69.

31 T.C.M. 39 (1972)

T.C. Memo. 1972-16

Ridgewood Land Company, Inc. v. Commissioner.

United States Tax Court.

Filed January 19, 1972.


Attorney(s) appearing for the Case

Hugh C. Montgomery, Jr., and Charles L. Brocato, 1801 Deposit Guaranty Bank Bldg., Jackson, Miss., for the petitioner. J. Leon Fetzer, for the respondent.


Memorandum Findings of Fact and Opinion

WITHEY, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended September 30, 1966, in the amount of $3,681.40.

The issue presented for decision is (1) whether petitioner realized ordinary income rather than long-term capital gain as reported from the sale of acreage under the threat of condemnation by the State of Mississippi Highway Department; and (2) alternatively...

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