- 148 - 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 thePage: Previous 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 Next
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