GARCIA v. COMMISSIONER

Docket No. 15771-79.

80 T.C. 491 (1983)

PHILLIP M. GARCIA AND DEBORAH H. GARCIA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 7, 1983.


Attorney(s) appearing for the Case

Harold O. Adams, for the petitioners.

Miles D. Friedman, for the respondent.


HAMBLEN, Judge:

Respondent determined a deficiency of $24,830 in petitioners' 1977 Federal income tax. After concessions, the issues for decision are:

(1) Whether petitioners' disposition of one parcel of real property and acquisition of another qualified as a like-kind exchange under section 1031(a).1

(2) If so, whether petitioners must recognize any gain on the exchange...

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