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property on January 20, 1994, should be recognized for purposes
of determining whether petitioners are entitled to nonrecognition
treatment under section 1033 with respect to the condemnation
proceeds that OIP received. Respondent contends that the record
shows that there was no valid nontax business reason for the
alleged purchase by OIP from IRF and that that alleged purchase
"was not bona fide, but was a sham transaction for tax purposes."
In support of that contention, respondent maintains, inter alia,
that there was no valid nontax business reason for the purported
transfers of the Vero Beach property by OIP to FIIC and by FIIC
to IRF; those purported transfers also were sham transactions for
tax purposes; the deed relating to the alleged sale by IRF to OIP
of the 34.3-acre parcel of the Vero Beach property was not
recorded, nor was the deed relating to the alleged transfer by
FIIC to IRF recorded; OIP allegedly paid $950,000 for the 34.3-
acre parcel of the Vero Beach property, through issuance of a
note, which was "264% of the cost of the larger parcel [the
entire 174.5-acre Vero Beach property] four months earlier", when
the deed was recorded purportedly transferring the entire Vero
Beach property from OIP to FIIC for only $360,000, the value of
that entire property based on the amount of Florida document
stamps paid; no Florida intangibles tax or Florida transfer tax
was paid with respect to the purported transfer of the Vero Beach
property from FIIC to IRF or with respect to the purported
transfer by IRF to OIP of the 34.3-acre parcel of the Vero Beach
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