T.C. Memo. 1997-109
UNITED STATES TAX COURT
TERRY D. SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 843-95. Filed March 3, 1997.
Richard E. Marsh, Jr., for petitioner.
James E. Gray and Paul G. Topolka, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a deficiency of $33,242
in petitioner's Federal income tax for 1990.
The issue for decision is whether petitioner may defer
recognition of gain realized on the sale of two properties
pursuant to section 1031(a). We hold that he may not because he
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