-33-
properties. In 124 Front Street, Inc. v. Commissioner, 65 T.C. 6
(1975), the taxpayer owned an option to purchase property that
Fireman's Insurance Company (Fireman's) wanted to acquire.
Fireman's advanced to the taxpayer the funds to acquire the
property so that the taxpayer could exchange the property for
property owned by Fireman's. We held that the transaction was a
like-kind exchange and that the advance, which was bona fide, was
not boot to the taxpayer. Id. at 15-16; see also Biggs v.
Commissioner, 69 T.C. 905 (1978), affd. 632 F.2d 1171 (5th Cir.
1980). In the instant case, as in 124 Front Street, Inc., there
is no evidence that the advances that were made by petitioners
were not bona fide. Petitioners acquired 29 Hastings in a
transaction that will be respected for tax purposes. See, e.g.,
Estate of Bowers v. Commissioner, 94 T.C. 582, 590 (1990); Biggs
v. Commissioner, supra at 918 (courts have afforded great
latitude in structuring exchanges under section 1031).
Section 1031(a) provides the general rule that "No gain or
loss shall be recognized on the exchange of property held solely
for productive use in a trade or business or for investment if
such property is exchanged solely for property of like kind which
is to be held either for productive use in a trade or business or
for investment." Emphasis added. Petitioners exchanged two
pieces of real estate (the Detroit properties and the 8th Street
property) for one piece of real estate (29 Hastings) plus the
excess cash proceeds. Cash is not property of like kind to real
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