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petitioners. Petitioners retained title and equity in Sunshine
Liquor until they sold it.
Petitioners' argument implies that an intent on their part
to undertake an exchange should be sufficient to bring the
transactions within the ambit of section 1031. We cannot agree.
Although intent can be relevant in determining what events
transpired, it is not sufficient to cause these transactions to
fall within section 1031. Garcia v. Commissioner, 80 T.C. 491,
498 (1983); Biggs v. Commissioner, 69 T.C. 905, 915 (1978).
Rather these transactions constitute a purchase and subsequent
sale.
We hold that the transactions here are properly
characterized as a purchase followed by a sale. Accordingly,
there was no exchange within the meaning of section 1031.
Section 6654 provides an addition to tax for the failure to
pay estimated income tax. This addition to tax is mandatory
unless petitioners demonstrate that they come within one of the
computational exceptions of section 6654(e). The addition to tax
is imposed regardless of reasonable cause or extenuating
circumstances. Dodge v. Commissioner, 96 T.C. 172, 183 (1991),
affd. in part and revd. in part 981 F.2d 350 (8th Cir. 1992);
Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
Furthermore, they have not demonstrated that they come within any
exception or that they had reasonable cause or extenuating
circumstances. Petitioners failed to make any estimated tax
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