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exchange requirement is to have any significance at
all, the perhaps formalistic difference between the two
types of transactions must, at least on occasion,
engender different results. Accord, Starker v. United
States, 602 F.2d 1341, 1352 (9th Cir. 1979).
Petitioners argue (1) that the four properties acquired by
OIP (i.e., the Brentwood property, Mr. Canty's residence, the
Vero Beach property, and the Quail Ridge property) are like-kind
properties within the meaning of section 1031(a) and (2) that
those properties (a) were identified, as required by section
1031(a)(3)(A), within 45 days after OIP disposed of lots 11 and
12 and OIP's 25-percent interests in lots 14 and 15 and (b) were
acquired within the time prescribed by section 1031(a)(3)(B).
According to petitioners, OIP's disposition of lots 11 and 12 and
OIP's 25-percent interests in lots 14 and 15 and its acquisition
of those four properties were steps in an integrated transaction,
the substance of which was an exchange of properties qualifying
under section 1031. In support of that position, petitioners
rely on cases involving multiparty transactions which the courts
have characterized as exchanges under section 1031, including
Biggs v. Commissioner, 632 F.2d 1171 (5th Cir. 1980), affg. 69
T.C. 905 (1978); W.D. Haden Co. v. Commissioner, 165 F.2d 588
(5th Cir. 1948), affg. on this issue a Memorandum Opinion of this
Court dated Apr. 9, 1946; Garcia v. Commissioner, 80 T.C. 491
(1983); and Barker v. Commissioner, supra.
Respondent does not dispute that the Brentwood property, the
Vero Beach property, and the Quail Ridge property are like-kind
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