- 12 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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