Revenue Ruling 79-261
Internal Revenue Service
1979-2 C.B. 295 (1979)
Facts
A taxpayer corporation was engaged in the banking business. The corporation owned an office building that the corporation leased to produce rental income. In 1977, after a tornado destroyed the office building, the corporation received insurance proceeds that the corporation used to build a new office building. The corporation conducted banking business out of part of the new building but leased the rest of the building to produce rental income under leases that were similar to the leases between the corporation and tenants in the original building. Section 1033(a) of the Internal Revenue Code provides for nonrecognition of gain on the involuntary conversion of a taxpayer’s property into replacement property that is similar or related in service or use. The Internal Revenue Service (IRS) issued a revenue ruling regarding whether the corporation’s use of the insurance proceeds to build the new building—which the IRS described as the reinvestment of proceeds from an involuntary conversion—qualified as a replacement of the office building with property that was similar or related in service or use for purposes of § 1033.
Rule of Law
Issue
Holding and Reasoning ()
What to do next…
Here's why 710,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 44,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
