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BEHRENS v. COMMISSIONER

Docket No. 20583-82.

49 T.C.M. 1284 (1985)

T.C. Memo. 1985-195

Frederick W. Behrens and Ethel Behrens v. Commissioner.

United States Tax Court.

Filed April 23, 1985.

Attorney(s) appearing for the Case

Robert J. Murray, 10306 Regency Parkway Drive, Omaha, Neb., for the petitioners. Robert L. Archambault, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in the amount of $11,363.70 in petitioners' 1978 Federal income tax. After concessions by petitioners,1 the sole issue for decision is whether petitioners must recognize gain in the amount of $22,080.37 on a transaction in which they traded in four old truck tractors for four new truck tractors. Resolution of this issue depends

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