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PITTSBURGH TERMINAL CORPORATION v. COMMISSIONER

Docket No. 562-71.

60 T.C. 80 (1973)

PITTSBURGH TERMINAL CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 23, 1973.

Attorney(s) appearing for the Case

Monroe Guttmann (an officer), for the petitioner.

Louis A. Boxleitner, for the respondent.

IRWIN, Judge:

Respondent determined a deficiency of $58,655.37 in the income tax of petitioner for 1966. The ultimate question to be decided is whether petitioner had any allowable capital loss from sale of coal lands in 1966; however, the decision on this question depends upon the resolution of the following issues:

(1) Whether the cost basis of coal lands acquired by Terminal Railroad & Coal Co. (Terminal Coal No. I) exceeded the deductions for...

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