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KOCH v. COMMISSIONER

Docket No. 9648-76.

71 T.C. 54 (1978)

CARL E. KOCH AND PAULA KOCH; FREDERICK W. KOCH AND ROBIN E. KOCH, A.K.A., ROBIN E. PRUITT; WILLIAM A. BOMBERGER AND CAROLYN L. BOMBERGER; AND JOHN J. KOCH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 23, 1978. estate which were subject to 99-year condominium leases. Held, the properties so exchanged are properties of a like kind within the meaning of sec. 1031(a), I.R.C. 1954, and no gain is recognized on the exchanges.

Attorney(s) appearing for the Case

Michael D. Annis and Michel G. Emmanuel, for the petitioners.

Robert J. Shilliday, Jr., and William D. Brackett, for the respondent.

FEATHERSTON, Judge:

In this case,1 respondent determined deficiencies in petitioners' Federal income tax for the years 1972, 1973, and 1974, as follows:

       Petitioners                      1972          1973           1974

Carl E. Koch and Paula Koch ......   $24,601.09    $248,222.50    $417,808.50
Frederick W. Koch and Robin E.
 Koch (a.k.a. Robin E. Pruitt) ...         0      ...

                    
                    

                        

                            

                                

                                    
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