7
desired replacement properties); in fact none were asked, and
none were performed.
On September 20, 1991, the corporation notified the Citizens
National Bank, as escrow agent, of the designation of three
properties which the corporation intended as replacement
properties for the purposes of section 1031(a)(3). These
properties were designated as the "McClure quarries in Tennessee
Township, Colchester, Illinois," which were not acquired by the
corporation; the Coggeshall property; and "property zoned M-2
located south and east of Route 41 in Galesburg Township, Knox
County, Illinois" (owner and size not specified).
On January 30, 1992, the corporation, Scott Coggeshall, and
the Coggeshall Co. executed a purchase agreement (Coggeshall
purchase agreement) with respect to the Coggeshall property for a
total purchase price of $577,370, including $321,000 for the real
estate owned by Scott Coggeshall and the asphalt plant located
thereon owned by the Coggeshall Co. and $256,370 for other
miscellaneous equipment, including the asphalt plant owned by the
Coggeshall Co., but located on land owned by Collins. Payment
for this purchase was accomplished by an immediate payment of
$300,000 at closing to the sellers, as a downpayment, with the
$277,370 balance to be payable over 4 years. This arrangement
for deferred payment was solemnized by a second escrow agreement
established by the parties with the Citizens National Bank of
Macomb. The Coggeshall property was to be held by the
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