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RAINIER COMPANIES, INC. v. COMMISSIONER

Docket No. 6870-71.

36 T.C.M. 1404 (1977)

T.C. Memo. 1977-351

Rainier Companies, Inc. (formerly Sicks' Rainier Brewing Co.) v. Commissioner.

United States Tax Court.

Filed October 3, 1977.

Attorney(s) appearing for the Case

F.A. LeSourd, 1300 Seattle Tower, Seattle, Wash., for the petitioner. Richard J. Shipley, for the respondent.

Supplemental Memorandum Opinion

IRWIN, Judge:

Our original opinion in this case (61 T.C. 68) was filed on October 23, 1973. The decision dealt with three issues, to wit:

(1) Whether petitioner's sale of its baseball stadium site to the City of Seattle was an involuntary conversion under threat of condemnation entitling petitioner to defer recognition of the gain under section 1033;1

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