-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.
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