Allegheny County Auto Mart, Inc. v. Commissioner of Internal Revenue

Third Circuit

Allegheny County Auto Mart, Inc. v. Commissioner of Internal Revenue

208 F.2d 693, 45 A.F.T.R. (P-H) 7, 1953 U.S. App. LEXIS 4059

CourtCourt of Appeals for the Third Circuit

DecidedDecember 29, 1953

Docket11129

StatusPublished

Cited by5 cases

This text of 208 F.2d 693 (Allegheny County Auto Mart, Inc. v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Allegheny County Auto Mart, Inc. v. Commissioner of Internal Revenue, 208 F.2d 693, 45 A.F.T.R. (P-H) 7, 1953 U.S. App. LEXIS 4059 (3d Cir. 1953).

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Opinion

PER CURIAM.

This petition to review a decision of the Tax Court with respect to the petitioner’s 1948 income tax involves the purely factual question whether its purchase of premises 5820 Baum Boulevard, Pittsburgh, from Meyer Marcus and its contemporaneous sale to him of premises 5860 Baum Boulevard were separate transactions or were part of a single transaction. The Tax Court, in a memorandum opinion by Judge Murdock, found that “The disposition of 5860 and the acquisition of 5820 were parts of a single inseparable deal in which the petitioner transferred 5860 as a part of the consideration for 5820”. This finding has adequate support in the evidence and it compels the conclusion which the Tax Court reached that the petitioner did not realize a taxable loss on the disposition of 5860.

The decision of the Tax Court will be affirmed.

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PER CURIAM.

This petition to review a decision of the Tax Court with respect to the petitioner’s 1948 income tax involves the purely factual question whether its purchase of premises 5820 Baum Boulevard, Pittsburgh, from Meyer Marcus and its contemporaneous sale to him of premises 5860 Baum Boulevard were separate transactions or were part of a single transaction. The Tax Court, in a memorandum opinion by Judge Murdock, found that “The disposition of 5860 and the acquisition of 5820 were parts of a single inseparable deal in which the petitioner transferred 5860 as a part of the consideration for 5820”. This finding has adequate support in the evidence and it compels the conclusion which the Tax Court reached that the petitioner did not realize a taxable loss on the disposition of 5860.

The decision of the Tax Court will be affirmed.

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Bluebook (online)

208 F.2d 693, 45 A.F.T.R. (P-H) 7, 1953 U.S. App. LEXIS 4059, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allegheny-county-auto-mart-inc-v-commissioner-of-internal-revenue-ca3-1953.

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