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CROWLEY, MILNER & CO. v. COMMISSIONER

Docket No. 8828-78.

76 T.C. 1030 (1981)

CROWLEY, MILNER & COMPANY, A MICHIGAN CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 17, 1981.

Attorney(s) appearing for the Case

Joel J. Morris and Thomas L. Geer, for the petitioner.

Thomas E. Ritter, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $159,724.57 and an addition to tax under section 6651(a)1 in the amount of $919.61 for the tax year ended January 31, 1976. The issues for decision are:

(1) Whether section 1031 applies to a sale-leaseback entered into by petitioner and Prudential Insurance Co. of America;

(2) Whether the loss incurred by petitioner on the transaction should...

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