-6-
1031(a)(3)(B)(ii) does not apply herein because the due date for
petitioners' 1993 Federal income tax return was April 15, 1994,
which is later than the 180 day requirement.) Thus, the
Murfreesboro Road property is property which is not like-kind.
Petitioners assert they should not have to recognize gain on
the exchange because they made a good faith attempt to adhere to
the statute. In essence, petitioners request that the Court ignore
the plain language of the statute and essentially rewrite it to
achieve what would be an equitable result. See Hildebrand v.
Commissioner, 683 F.2d 57, 58-59 (3d Cir. 1982), affg. T.C. Memo.
1980-532. Although we are sympathetic to petitioners' plight, we
do not have jurisdiction to do as petitioners request. Regrettably
for petitioners, this Court is not a court of equity and does not
possess general equitable powers. Stovall v. Commissioner, 101
T.C. 140, 149-150 (1993) (citing Commissioner v. McCoy, 484 U.S. 3
(1987)); Woods v. Commissioner, 92 T.C. 776, 787 (1989). The
Internal Revenue Code, not general equitable principles, is the
mainspring of this Court's jurisdiction. Commissioner v. Gooch
Milling & Elevator Co., 320 U.S. 418, 422 (1943).
Petitioners claim that Internal Revenue Service (IRS) should
take a more "citizen-friendly" position than respondent asserts
herein. Petitioners philosophize that if circumstances beyond
their control prevent them from purchasing replacement property
within the 180-day period, then the time for acquiring replacement
property pursuant to section 1031 should be the same as the time
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