Julius and Hanan Dibsy - Page 12

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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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