Orville E. Christensen and Helen V. Christensen - Page 5

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          the property to petitioner husband, who in turn transferred the             
          same to petitioners as trustees for the Christensen trust.                  
               5.  On June 16, 1989, the facilitators transferred the                 
          property known as Haystack Landing to petitioner husband, who in            
          turn transferred the property to petitioners as trustees for the            
          Christensen trust.                                                          
               6.  On April 26, 1989, Jeffrey and Sandra Bohn transferred             
          the property known as the Greenville property to petitioners as             
          trustees for the Christensen trust.                                         
               With respect to all these transfers of property, except as             
          section 1031(a)(3) may apply, petitioners received no money or              
          other nonqualifying property from the facilitators or otherwise             
          as the result of transferring the Tesconi property.                         
               As part of their 1988 joint income tax return, petitioners             
          included the statement "the property known as 360 Tesconi Circle            
          is being exchanged in a deferred 'starker' exchange.  The                   
          transaction will be completed and reported in 1979".  The use of            
          "1979" in this statement is a typographical error that should               
          read "1989".                                                                
               No issue is raised by the parties, and they apparently agree           
          that the Tesconi property relinquished by petitioner husband and            
          the properties received by him were like-kind properties which              
          would qualify for exchange under section 1031(a)(1).  Likewise,             
          the parties apparently agree that there was no cash boot or other           
          nonqualifying property received in this set of transactions under           




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