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WEYL-ZUCKERMAN & COMPANY v. COMMISSIONER

Docket No. 43504.

23 T.C. 841 (1955)

WEYL-ZUCKERMAN & COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 14, 1955.

Attorney(s) appearing for the Case

David Livingston, Esq., and Louis F. DiResta, C. P. A., for the petitioner.

Charles W. Nyquist, Esq., for the respondent.

Respondent determined a deficiency in the income tax of petitioner for the year 1947 in the amount of $66,082.54.

The sole question is whether, in determining petitioner's basis for gain or loss of gas rights in a tract of land known as the Henning Tract, transactions involving a transfer of these rights by petitioner to a wholly owned subsidiary in June of 1946 and a reconveyance back to petitioner in December of 1946 should...

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