- 9 -
v. Commissioner, 412 F.2d 800, 801 (3d Cir. 1969), affg. per
curiam T.C. Memo. 1968-126; Estate of Hall v. Commissioner, 92
T.C. 312, 337-338 (1989); Lare v. Commissioner, 62 T.C. 739, 750
(1974) ("Statements made in a tax return signed by a taxpayer may
be treated as admissions."), affd. without published opinion 521
F.2d 1399 (3d Cir. 1975); Rankin v. Commissioner, T.C. Memo.
1996-350; Sirrine Bldg. No. 1 v. Commissioner, T.C. Memo. 1995-
185 ("As statements of a party opponent, the returns are
admissions under rule 801(d)(2) of the Federal Rules of
Evidence."); Estate of Ford v. Commissioner, T.C. Memo. 1993-580,
affd. 53 F.3d 924 (8th Cir. 1995); Mooneyham v. Commissioner,
T.C. Memo. 1991-178; Estate of McGill v. Commissioner, T.C. Memo.
1984-292; Estate of Kreis v. Commissioner, T.C. Memo. 1954-139,
affd. 227 F.2d 753 (6th Cir. 1955); see United States v. Dinnel,
428 F. Supp. 205, 208 (D. Ariz. 1977) ("Statements made in an
income tax return constitute admissions."), affd. without
published opinion 568 F.2d 779 (9th Cir. 1978); Kaltreider v.
Commissioner, 28 T.C. 121 (1957), affd. 255 F.2d 833 (3d Cir.
1958). There is no cogent or persuasive evidence that petitioner
identified the replacement property before April 1, 1990. When
petitioner saw the East Boulevard property on February 27, 1990,
he liked the location, but he thought the price was too high, he
had specific requirements for financing terms, he knew he would
need to make (and arrange financing for) extensive renovations,
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