David A. and Marilyn P. Knight - Page 7

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          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.                          












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