Memorandum Opinion
WITHEY, Judge:
Respondent determined a deficiency in petitioner's income tax for 1958 in the amount of $23,481.43.
The sole issue presented for our decision is whether gain realized by petitioner from the condemnation of its real property by the City of New York qualifies for nonrecognition under section 337(a) of the Internal Revenue Code of 1954.
All of the facts have been stipulated and are hereby found as stipulated...
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