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STEUART BROS., INC. v. COMMISSIONER

Docket No. 60494.

29 T.C. 372 (1957)

STEUART BROS., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 27, 1957.

Attorney(s) appearing for the Case

Robert P. Smith, Esq., for the petitioner.

William Schwerdtfedger, Esq., for the respondent.

OPINION.

TRAIN, Judge:

The Commissioner determined a deficiency of $81,162.37 in the income tax of petitioner for the calendar year ended December 31, 1951. The only issue is whether petitioner reinvested the proceeds from condemnation proceedings in "property similar or related in service or use" to the property condemned within the meaning of section 112 (f) of the Internal Revenue Code of 1939.

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