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PW’s 2000 sale of her 12-percent LLC membership
interest.
Vivian D. Hoard and Patti M. Richards, for petitioners.
Michael L. Scheier and Jennifer J. Morales, for affected
person United Surgical Partners International, Inc.
Brenda M. Fitzgerald, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated April 10,
2003 (the notice), respondent determined deficiencies in
petitioners’ Federal income tax as follows:
Year Deficiency
1999 $96,925
2000 78,578
By the petition, petitioners assign error to respondent’s
deficiency determination. The parties have resolved certain
issues.1 The remaining issues for decision are whether (1)
petitioners’ purported exchange of vacation properties qualifies
as a tax-free “like-kind” exchange of properties under section
1 Those issues are (1) issues settled or conceded pursuant
to the parties’ stipulation of settled issues executed on May 19,
2004, and (2) issues that petitioners failed to pursue on brief,
which we treat as having been abandoned. See Nicklaus v.
Commissioner, 117 T.C. 117, 120 n.4 (2001). The issues that
petitioners failed to pursue are (1) whether petitioners are
required to include in income for 1999 $1,701 of interest and (2)
whether petitioner Barry E. Moore is entitled to relief from tax
liability for either 1999 or 2000 as an innocent spouse.
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