-7- for acquiring replacement property where there is an involuntary conversion; and thus, the 180-day period should be extended to 2 years. Petitioners read IRS Publication 544, Sales and Other Dispositions of Assets, to support their philosophy. Although we do not read IRS Publication 544 in the way petitioners do, nonetheless, it is well settled that authoritative tax law is contained in statutes, regulations, and judicial decisions and not in informal publications. See Zimmerman v. Commissioner, 71 T.C. 367, 371 (1978), affd. without published opinion 614 F.2d 1294 (2d Cir. 1979); Green v. Commissioner, 59 T.C. 456, 458 (1972). Internal Revenue Service publications, like the one upon which petitioners relied, are merely guides published by the IRS to aid taxpayers. See Dixon v. United States, 381 U.S. 68, 73 (1965). Petitioners do not dispute respondent's computations as to the amount of gain realized from the disposition of the two rental properties in Wisconsin. Accordingly, respondent's computations are sustained. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011