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ARMENDARIS CORP. v. COMMISSIONER

Docket No. 7938-76.

72 T.C. 52 (1979)

THE ARMENDARIS CORPORATION (FORMERLY ARMENDARIS LAND DEVELOPMENT CORPORATION), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 4, 1979.

Attorney(s) appearing for the Case

Reed O. Gentry and Jack B. Robertson, for the petitioner.

James E. Cannon, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for its fiscal year ending April 30, 1971, in the amount of $150,605.72. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision the following:

(1) Whether the provisions of section 1251, I.R.C. 1954,1 apply to dispositions of farm property by petitioner during its fiscal year ending...

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