Teruya Brothers, Ltd. & Subsidiaries - Page 20

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          section 1031(a)(1), to defer the gains that it realized on the              
          exchanges of Ocean Vista and Royal Towers.14                                

                                             An appropriate order will be             
                                        issued denying petitioner’s motion            
                                        to supplement the record, and                 
                                        decision will be entered for                  

               14 On Sept. 8, 2004, petitioner filed a motion to supplement           
          the record with three letters from respondent to petitioner.                
          Each of these letters concerns a technical advice memorandum that           
          involves a multiparty transaction among a taxpayer, a qualified             
          intermediary, and a related person.  In a rambling 96-page reply            
          brief, petitioner contends that these letters provide an                    
          abundance of evidence that respondent has been improperly                   
          administering sec. 1031(f)(4).  Because we find that the letters            
          petitioner submitted have no relevance to the issues in this                
          case, we will deny petitioner’s motion to supplement the record.            

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