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VALLEY TITLE CO. v. C. I. R.

No. 75-2527.

559 F.2d 1139 (1977)

VALLEY TITLE COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

August 24, 1977.

Attorney(s) appearing for the Case

Michael C. Ferguson, Berkeley, Cal., argued for petitioner-appellant.

Meade Whitaker, Chief Counsel, IRS, M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Chief, Appellate Section, Tax Div., U. S. Dept. of Justice, Washington, D. C., for respondent-appellee.

Before MERRILL and TRASK, Circuit Judges, and TAKASUGI, District Judge.

MERRILL, Circuit Judge:

This appeal is taken from the decision of the tax court, 34 T.C.M. (CCH) 312 (1975), upholding the Commissioner in his disallowance of a loss claimed by taxpayer, Valley Title Company. Whether a loss was sustained is the question before us.1 Taxpayer claimed a loss in connection with an exchange by taxpayer of an unimproved parcel of land owned by it, located on Second Street, San...

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