This section contains the nature of the case and procedural background.

P was forced to sell his office building to the City of Cincinnati under threat of eminent domain. P held the building for the production of income. P then used the funds from the proceeds of that sale to purchase 80% of the Times Square Hotel of New York, an Ohio corporation that as its sole asset had a contract to buy the Times Square Hotel of New York City. The purchase of the hotel was affected by the corporation. The IRS did not view the sale as a similar one or one related in service to use to the office building; thus, it gave no recognition under 1033(a)(3)(A). P contends that both properties were productive rental income. The tax court agreed with the IRS.

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