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RAMEY INVESTMENT CORPORATION v. COMMISSIONER

Docket No. 1414-65.

26 T.C.M. 17 (1967)

T.C. Memo. 1967-4

Ramey Investment Corporation (Formerly Ramey Air Base Homes, Inc.) v. Commissioner.

United States Tax Court.

Filed January 11, 1967.

Attorney(s) appearing for the Case

George E. Grimball, Jr., 7 Broad St., Charleston, S. C., and J. C. Long, 90 Broad St., Charleston, S. C., for the petitioner. Winfield A. Gartner and J. Larry Broyles, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency of $485,963.13 in petitioner's income tax for its taxable year ended October 31, 1958.

The issues presented for our decision are:

1. Did petitioner's gain on the sale, under threat of condemnation, of its rental housing project in Puerto Rico in the taxable year ended October 31, 1958, constitute gross income within the meaning of section 931 of the...

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