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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
respondent.
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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