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TOWN PARK HOTEL CORP. v. COMMISSIONER

Docket No. 2531-69.

29 T.C.M. 1150 (1970)

T.C. Memo. 1970-261

Town Park Hotel Corporation v. Commissioner.

United States Tax Court.

Filed September 14, 1970.

Attorney(s) appearing for the Case

Charles M. Collins (an officer), and Wayne C. Marsh, Holiday Inns of America, Inc., Memphis, Tenn., for the petitioner. Jack D. Yarbrough, for the respondent.

Memorandum Opinion

TIETJENS, Judge:

The Commissioner determined a deficiency in petitioner's Federal income tax for the fiscal year ended June 30, 1965 in the amount of $112,223.74. The only issue presented for our decision is whether petitioner reinvested the proceeds received on the condemnation of its property within the time limit of section 1033 (a)(3)(B)(i), I. R. C. 1954,1 and thereby was entitled to treat the gain thereon...

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