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ESTATE OF GREGG v. COMMISSIONER

Docket No. 5580-76.

69 T.C. 468 (1977)

ESTATE OF HARRY A. GREGG, HUGH GREGG, EXECUTOR, AND HARRIETT H. GREGG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 12, 1977.

Attorney(s) appearing for the Case

Robert J. McDonough, for the petitioners.

Barry J. Laterman, for the respondent.

OPINION

TIETJENS, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax in the amount of $227,948. The issue is whether the replacement of condemned property after the death of the grantor of a grantor trust may qualify for nonrecognition treatment under section 1033.

This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and attached exhibits are...

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