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POPE & TALBOT, INC., & SUBS. v. COMMISSIONER

Docket No. 530-93.

104 T.C. 574 (1995)

POPE & TALBOT, INC., & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 8, 1995.

Attorney(s) appearing for the Case

Grady M. Bolding, James E. Burns, Jr., Russell D. Uzes, and Kevin P. Muck, for petitioner.

Milton J. Carter, Jr., Christopher D. Hatfield, and William McCarthy, for respondent.

OPINION

RUWE, Judge:

Respondent determined deficiencies in petitioner's 1985 and 1986 Federal income taxes in the amounts of $17,693,960 and $954,678, respectively. Petitioner has filed a motion for partial summary judgment, and respondent has filed a cross-motion for partial summary judgment. The sole issue presented by these motions is whether gain from the distribution of appreciated property under section 311(d)1 is...

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