United States Tax Court April 23, 1973, Docket No. 562-71 (Pittsburgh Terminal Corp. v. Commissioner)

lead-opinion

IRWIN, Judge:

Respondent determined a deficiency of $58,655.37 in the income tax of petitioner for 1966. The ultimate question to be decided is whether petitioner had any allowable capital loss from sale of coal lands in 1966; however, the decision on this question depends upon the resolution of the following issues:

(1) Whether the cost basis of coal lands acquired by Terminal