T.C. Memo. 1997-73
UNITED STATES TAX COURT
LARRY L. BEELER AND CYNTHIA J. BEELER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16052-94. Filed February 10, 1997.
J. Paul Raymond and Marie De Marco, for petitioners.
Judith C. Winkler and Benjamin A. de Luna, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a deficiency of
$266,375 in petitioners' income tax for 1991.
After concessions, the issue for decision is whether
petitioners may defer recognition of all of the gain that they
received for an exchange involving real property in 1991 under
section 1031, as petitioners contend, or only part of the gain,
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