David A. and Marilyn P. Knight - Page 3

                                         -3-                                          
          properties.                                                                 
               On February 17, 1993, petitioners sold their 99th Street               
          property for $135,000.  On February 19, 1993, they sold the West            
          Center Street property for $136,000.                                        
               On April 2, 1993, petitioners identified the following three           
          potential replacement properties:  (1) A 100- by 300-foot parcel in         
          Franklin, Tennessee; (2) 2902 Campbellsville Pike, Columbia,                
          Tennessee (Campbellsville Pike property); and (3) 2711 Murfreesboro         
          Road, Antioch, Tennessee (Murfreesboro Road property).                      
               Petitioners immediately began negotiations to acquire the 100-         
          by 300-foot parcel in Franklin, Tennessee, but these negotiations           
          ended without an agreement.  Then, petitioners attempted to acquire         
          the Campbellsville Pike property.  An agreement to purchase that            
          property was reached, but on August 16, 1993, the sellers of the            
          property canceled the sale.                                                 
               On December 23, 1993, petitioners purchased the Murfreesboro           
          Road property for $321,750.  The acquisition of the property was            
          more than 180 days from the respective dates the 99th Street and            
          West Center Street properties were sold.                                    
          Federal Income Tax Returns                                                  
               On Forms 8824, Like-Kind Exchanges, attached to their 1993             
          Federal income tax and amended returns, petitioners elected to              
          defer the gain realized on the sale of their two residential rental         
          properties.                                                                 






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