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agreed to transfer to Mr. and Mrs. Wilson as "facilitators", for
further transfer to Mr. and Mrs. Klotz and Mr. and Mrs. Falconer
as "purchasers", the Tesconi property, as part of a contemplated
tax-free exchange under the provisions of section 1031. In
addition, the exchanger agreed to notify the facilitators of the
property that the exchanger desired to acquire within 45 days
after the closing date of the transfer to facilitators of the
Tesconi property in order to complete the projected exchange.
Further, the agreement specified that such property to be
received by petitioner husband as exchanger in the projected
exchange would be acquired by him "no later than 180 days after
the closing date (but not later than the due date (taking into
account extensions) of Exchanger's Federal income tax returns for
the taxable year in which Exchanger's property was transferred to
Facilitator)".
On the same date mentioned above, December 22, 1988,
petitioner husband transferred the Tesconi property to the
facilitators, and on that same date the facilitators transferred
said property to the purchasers. No consideration for the
transfer was received at that time.
On February 3, 1989, petitioner husband sent the
facilitators a letter listing the properties that he desired to
acquire as part of the projected exchange. Nineteen such
properties were listed, and were identified by the Sonoma County
(California) county assessor's parcel numbers, except for one
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