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Internal Revenue Code in effect for the taxable year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulations of facts and the attached exhibits are incorporated
herein by this reference. Petitioners resided in Franklin,
Tennessee, at the time they filed their petition and amended
petition. At all relevant times, petitioners were realtors.
Before the year under consideration, petitioners resided in
Milwaukee, Wisconsin. There, they owned two residential rental
properties: 3460 North 99th Street (99th Street property) and 7643
West Center Street (West Center Street property). Petitioners had
purchased the 99th Street property for $126,000 in July 1991 and
the West Center Street property for $118,500 in 1986.
In 1993, petitioners moved to Franklin, Tennessee. They
decided to dispose of these two residential rental properties by
exchanging them for like-kind property pursuant to section 1031.
Accordingly, petitioners entered into two accommodation agreements
with Heritage Title Services, Inc. (accommodation agreements),
pursuant to which they agreed to sell the two residential rental
properties and purchase other qualifying like-kind property in
Tennessee as part of a tax-free exchange. The accommodation
agreements required petitioners to identify replacement properties
within 45 days after the date of the closing on the two rental
properties and to receive the qualifying like-kind property within
180 days after the date of the closing on the two rental
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