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SANTUCCI v. COMMISSIONER

Docket No. 6345-71.

32 T.C.M. 840 (1973)

T.C. Memo. 1973-178

Arnold L. Santucci and Vida L. Santucci v. Commissioner.

United States Tax Court.

Filed August 8, 1973.

Attorney(s) appearing for the Case

Leland H. Dibble, Jr., 837 Fifth St., Santa Rosa, Calif., for petitioners. Peter D. Bakutes, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined a deficiency of $1,576.54 in the income tax of petitioners for the calendar year 1968. The sole issue for decision is whether petitioners' subsequent reinvestment of proceeds from a condemnation award causes the gain realized on such sale to be deferred by reason of section 1033(a)(3)1 when such gain had been recognized by petitioners on their return...

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