SIRBO HOLDINGS, INC. v. COMMISSIONER

Docket No. 515-69.

61 T.C. 723 (1974)

SIRBO HOLDINGS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 13, 1974.


Attorney(s) appearing for the Case

Lester H. Salter, for the petitioner.

Marwin A. Batt and Marion L. Weston, for the respondent.


SUPPLEMENTAL OPINION

QUEALY, Judge:

In our opinion entered January 27, 1972 (57 T.C. 530), on the basis of the facts in this case we held that the sum of $125,000 received by the petitioner in consideration for the "updating" of the restoration clause in a lease did not constitute an amount realized either from the sale or exchange of property or from the compulsory or involuntary conversion of property within the meaning...

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