- 10 - report any interest income received from the State. However, petitioners now concede that, for taxable year 1989, they had unreported postjudgment interest income from the State in the amount of $1,333.35.5 Petitioners never asked the Internal Revenue Service (IRS) for an extension of time in which to buy replacement property pursuant to section 1033. Furthermore, petitioners did not, prior to October 1991, notify the IRS that they had bought replacement property with the condemnation proceeds. In 1989, petitioners purchased property in Bath County, Virginia (Bath Co. property), paying $125,000 for such property. In 1993, petitioners rented out the Bath County property with the agreement that the property would remain on the market and, if sold, the rental agreement would terminate. Petitioner called the IRS in the Spring of 1989, and he was referred to section 1033; after reviewing the code section, he concluded that he had acquired replacement property that complied with section 1033. In 1987, petitioners bought 691.043 shares of International Stock Fund from T. Rowe Price (stock fund) for the total amount of $19,750. In 1987, petitioners received distributions from the stock fund in the amount of $7,006.92. Petitioners reinvested this amount into the stock fund. In 1988, petitioners received 5 Although the parties stipulated that the postjudgment interest was $1,335.35, this appears to be a typographical error, as the schedule accompanying the State's deposit listed the postjudgment interest as $1,333.35. Accordingly, we find that the stipulated postjudgment interest income is $1,333.35.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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