-22- Investments, Limited to pay for Hong Kong Restaurant, Inc. The evidence does not support this claim. To summarize, Ms. Ng proved an initial basis of $36,750 in the stock of Hong Kong Restaurant, Inc. which was totally absorbed by pass-through losses she claimed prior to 1986. She did not prove any additional contributions to capital or shareholder loans. Accordingly, we hold that the deductions claimed during the years under consideration were properly disallowed. Issue 3. Section 1031 Exchange Ms. Ng deferred gain from the sale of her Larkin and Lombard Street properties in San Francisco pursuant to section 1031. The deferred gain from the sale of her Larkin Street property in 1988 was $393,177, and the deferred gain from the sale of her Lombard Street property in 1989 was $516,633. Ms. Ng's sale of her Larkin and Lombard Street properties was followed by Strong Hope's conveyance of its one-half interest in an apartment building at 850 Stockton Street in San Francisco to Ms. Ng. Ms. Ng owned the other half interest in the Stockton Street property. Respondent determined that Ms. Ng was not entitled to the deferred gain on the sale of these 2 properties on the ground that Ms. Ng did not intend to exchange the properties for like-kind property, as required to obtain deferral of gain under section 1031. The underlying facts support respondent's assertions. In July of 1988, Wing Lung Bank demanded that Ms. Ng satisfy her delinquent bank loans. Ms. Ng advised the bank that she wouldPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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