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HILL v. COMMISSIONER

Docket No. 1206-73.

66 T.C. 701 (1976)

J. CARL HILL AND MARY E. HILL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 14, 1976.

Attorney(s) appearing for the Case

Walter W. Woodside, for the petitioners.

Howard L. Williams, for the respondent.

WILES, Judge:

Respondent determined a $9,423.51 deficiency in petitioners' 1969 income taxes. There are two issues: (1) Whether petitioners are entitled to benefit from the nonrecognition provisions of section 1033;1 and (2) whether the basis of the property sold under threat of condemnation is more than that allowed in the statutory notice of deficiency and used in determining gain.

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