Brief Fact Summary. Petitioners ran an interstate trucking business. They used two adjacent pieces of property to operate the business. The threat of condemnation on one piece forced the sell of both parcels.
Synopsis of Rule of Law. A tax relief provision should be liberally construed to effectuate its purpose.
Held. Judge Kern issued the opinion for the Tax Court of the United States in finding for Petitioners that it was an involuntary conversion of both pieces of property.
Discussion. The Tax Court notes that because Petitioners needed both pieces of property adjacent to each other to effectively run their business, it was an involuntary conversion of both pieces of land. Even though the threat of condemnation was only on one piece, Petitioners bought the adjacent properties for their business and ran them as one economic unit. Further, after selling the original parcels, they bought similar land and continued to use it for the same economic purpose.