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

P operated an interstate trucking business. P bought at the same time two pieces of property across the street from each other. One was used for operations, and the other was used for parking. The two pieces were used as an economic unit. It is conceded, in this case, that the parking area was involuntarily converted by P as a result of a threat of imminence of condemnation. If P had retained the improved property, the closest area away for parking would have been 1.5 miles making operations physically and economically impracticable. Because of this dilemma, P sold the other lot to use the proceeds of both lots to buy suitable property in the same general area. P claimed that both lots were involuntarily converted. The IRS disagreed.

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