T.C. Memo. 1996-150
UNITED STATES TAX COURT
RAYMOND ST. LAURENT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23048-93. Filed March 25, 1996.
Bryan M. Dench, for petitioner.
William T. Hayes and Louise R. Forbes, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: Respondent determined a deficiency of
$125,887 in petitioner’s 1988 Federal income tax. After
concessions, the only issue remaining for decision is whether,
pursuant to section 1031(a), petitioner may defer recognition of
gain realized upon the sale of certain real property. Unless
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