13
Accordingly, we must hold that the requirements of section
1031(a)(3)(B) are unambiguous; the transfer of the replacement
properties to petitioner husband as exchanger took place after
the required receiving period; no extension of time for filing
the required return for 1988 was applied for or granted; and the
transfers involved in this case do not qualify for tax-free
treatment under section 1031.
Qualification of the Transaction for Reporting on the Installment
Basis
We have held that the alleged "exchange" of the Tesconi
property by petitioner husband in exchange for various designated
properties, all acquired in 1989, are not to be treated as a tax-
free exchange under section 1031; rather, it is a sale by
petitioner husband, in payment of which he received the
properties that we have listed herein. The parties have
stipulated that the gain on the disposition of the Tesconi
property was $776,441 after deducting basis, refinancing costs,
and expenses of sale. It is true, however, that although the
Tesconi property was conveyed to the facilitators and to the
purchasers on December 22, 1988, the compensation to petitioner
husband was not received until after April 17, 1989. Petitioners
argue that, if the Court should hold that the transaction herein
does not qualify for tax-free exchange treatment under section
1031, nevertheless it should qualify for installment sale
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