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automobile, a 1981 Buick, to make business trips on
behalf of H&B.
Petitioners also appear to argue that petitioner
received the Lincoln in a like-kind exchange under section
1031. We find petitioners' argument without merit.
Petitioner failed to introduce documentary evidence that
he received the Lincoln Mark VII in exchange for a tractor-
trailer, and there is no documentary evidence that
petitioner owned a tractor-trailer other than the one he
testified that he contributed to Pet-Don. Moreover, Pet-
Don, and not petitioner, was the record owner of the
Lincoln Mark VII at all relevant times. Essentially,
petitioners argue that they exchanged a tractor-trailer
which they did not own for an automobile which they did
not own. This is clearly beyond the scope of section 1031.
Furthermore, section 1031 requires that both the
property transferred and the property received in a like-
kind exchange be held primarily for productive use in a
trade or business, or for investment. Sec. 1031(a)(1).
Petitioners have not shown that they held the Lincoln
Mark VII for productive use in a trade or business or
for investment. Thus, even if we accepted petitioner's
characterization of the transaction, section 1031 would not
apply in this case. Accordingly, we reject petitioners'
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