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MAY DEPARTMENT STORES CO. v. COMMISSIONER

Docket No. 4021-72.

33 T.C.M. 1128 (1974)

T.C. Memo. 1974-253

The May Department Stores Company v. Commissioner.

United States Tax Court.

Filed September 23, 1974.

Attorney(s) appearing for the Case

Robert A. Schulman, 1625 K St., N.W., Washington, D.C., and Lyman G. Friedman, for the petitioner. Ted M. Riseling and John B. Turner, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent has determined a deficiency in Federal income tax in the amount of $326,889 against The May Department Stores Company for its taxable year ended January 31, 1965.

We are asked to decide if the value of a tract of land conveyed to petitioner on January 28, 1965, was properly excluded from petitioner's gross income as a contribution to its capital...

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