Walter L. Medlin - Page 63

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               A    That it was like a tax-free--that was the way, and                
               I’m not far off, but I think I’m off far enough.  I                    
               understand now that that was how you do a tax-free                     
               exchange.                                                              
               Q    Now, you considered yourself to be in the business                
               of buying and selling property.  Is that correct?                      
               A    Yes, pretty much.  Yes, sir.                                      
               Q    Did you think that because you were in the                        
               business of buying and selling property, that that                     
               impacted your ability to engage in tax-free exchanges?                 
               A    That was my business.                                             
               Q    Did you think that you could be in the business of                
               buying and selling properties, and still engage in tax-                
               free exchanges?                                                        
               A    Oh, yes.                                                          
               Q    I mean, as you sit here today, you know there’s a                 
               --                                                                     
               A    Yes, now I understand your question, and yes, sir.                
               Q    So back in the years at issue, did you know that                  
               there was this distinction about, even if you do it                    
               correctly, it may--a tax-free exchange may not be                      
               available to a dealer in property?                                     
               A    Yes, sir.  I understand that now.                                 
                                                                                     
          As we have stated previously in this opinion, we were not                   
          impressed with petitioner’s testimony at trial, generally, and we           
          were certainly not impressed with his supposed understanding of             
          tax free exchanges of property.  During the examinations of                 
          petitioner’s returns for 1985 through 1988, petitioner did not              
          discuss with the revenue agent his beliefs regarding tax free               
          exchanges, and the substantial evidence of concealment of the               






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