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BEELER v. COMMISSIONER

Docket No. 16052-94.

73 T.C.M. 1982 (1997)

T.C. Memo. 1997-73

Larry L. Beeler and Cynthia J. Beeler v. Commissioner.

United States Tax Court.

Filed February 10, 1997.

Attorney(s) appearing for the Case

J. Paul Raymond and Marie De Marco, Clearwater, Fla., for the petitioners. Judith C. Winkler and Benjamin A. de Luna, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined a deficiency of $266,375 in petitioners' income tax for 1991.

After concessions, the issue for decision is whether petitioners may defer recognition of all of the gain that they received for an exchange involving real property in 1991 under section 1031, as petitioners contend, or only part of the gain, as respondent contends...

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