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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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