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GREENE v. COMMISSIONER

Docket No. 6913-89.

62 T.C.M. 512 (1991)

T.C. Memo. 1991-403

Joanne H. Greene and Estate of Robert H. Greene, Deceased, Joanne H. Greene, Executor, Petitioners v. Commissioner.

United States Tax Court.

Filed August 15, 1991.

Attorney(s) appearing for the Case

J.H. Mitchell, Jr., 1801 Century Park East, Los Angeles, Calif., for the petitioners. Kathryn Vetter and Alan S. Beinhorn, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency in Mr. and Mrs. Greene's individual Federal income tax for the tax year ended December 31, 1981, in the amount of $137,161.

The issue presented is whether the gains on the sale of Mr. Greene's interests in two separate properties qualify for nonrecognition under section 1031.1

Findings of Fact

Some of the facts have...

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