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RPDS for purposes of the statutory provisions governing deferred
like-kind exchanges. Sec. 1031(a)(3).
In sum, we hold that petitioner must recognize gain realized
upon the disposition of his interest in RPDS only with respect to
the exchange of his interest in RPDS for the Sheffield lot.
To reflect concessions and the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011