
    Andrew P. Robinson, Petitioner, v. Commissioner of Internal Revenue, Respondent.
    Docket No. 14924.
    Promulgated July 6, 1928.
    
      John H. Burnett, Esq., for the petitioner.
    
      T. M. Mather, Esq., for the respondent.
   MEMORANDUM OPINION.

Littleton:

The Commissioner determined a deficiency of $4,236.13 for the calendar year 1919. Petitioner claims (1) that the deficiency is barred by the statute of limitation; (2) that said tract of land, consisting of 132 acres, sold in 1919 for $49,000, had a fair market value of $450 an acre on March 1, 1913. The Commissioner determined the March 1,1913, value of $150 an acre.

Petitioner is a resident of Chillicothe, Ohio, and was the owner of a farm near that city which he inherited from his father in 1875. In 1919 it was necessary for the United States Government to have a portion of this farm for use as a military post, afterwards known as Camp Sherman, and in that year the United States purchased 132 acres of the farm, paying the petitioner $49,000 therefor. The fair market value of the land on March 1, 1913, was $400 an acre.

Judgment will be entered under Rule 50.  