-8-
Information, Election under Code Sec. 1033(a)(2) Not to Recognize
Gain from Compulsory or Involuntary Conversions." In this
statement, Ms. Whitfield reduced the basis in the replacement
properties purchased by Mr. Wickersham by the amount of gain
recognized on the sale of the Peveto.3 Ms. Whitfield and
petitioners signed the 1989 return.
The Criminal Proceedings
On July 29, 1992, a grand jury returned an eight-count
superseding indictment (the indictment) in the case of United
3 The supplemental information statement reads as follows:
Charles T. Wickersham * * * elected in accordance with
Code Sec 1033(a)(2) and Reg 1.1033(a)-2 not to
recognize a realized gain in the amount of $350,000
from the involuntary conversion of a commercial rental
property. The realization of gain on, and the
involuntary conversion of, the business property
occurred during the taxable year ended December 31,
1989.
The property was acquired by the taxpayer on March 2,
1989, at a cost of $100,000. The property was sold on
August 22, 1989 for $450,000. The realized gain was
$350,000.
Taxpayer elected under Code Sec 1033(a)(2), and Reg.
1.1033(a)-2 not to recognize the gain on conversion
since replacement property was acquired, which taxpayer
claims to be similar or related in service or use to
the converted property. The adjusted basis of the
replacement property is as follows:
Cost of Northway Property $352,000
Cost of 16th Street Property 98,000
Total $450,000
Less: Realized gain not
recognized per this election (350,000)
Basis of replacement property $100,000
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