MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined a deficiency of $125,887 in petitioner's 1988 Federal income tax. After concessions, the only issue remaining for decision is whether, pursuant to section 1031(a), petitioner may defer recognition of gain realized upon the sale of certain real property. Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue, and all...
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