- 52 -
time of the exchange, petitioner held the Exchange Property
primarily for sale (as evidenced, inter alia, by its effort to
make the final map ready to be recorded, its efforts to lock in
lower city development fees, and its treatment of the Exchange
Property in its books and records). We conclude that the
Exchange Property was held by petitioner primarily for sale
within the meaning of section 1031(a)(2)(A) and therefore that
the exchange does not qualify for nonrecognition treatment under
section 1031(a).
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Last modified: May 25, 2011