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CONNERS v. COMMISSIONER

Docket No. 41651-85.

88 T.C. 541 (1987)

RAY R. AND MARY G. CONNERS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 5, 1987.

Attorney(s) appearing for the Case

Arthur A. Armstrong, for the petitioners.

Andrew D. Weiss, for the respondent.

OPINION

WRIGHT, Judge:

This case is before the Court on petitioners' motion for summary judgment upon the section 1038(a) issue. The issue for decision is whether petitioners are entitled to nonrecognition of gain pursuant to section 1038(a) with respect to real property which they reacquired in 1981.

Respondent determined a deficiency in petitioners' Federal income tax for calendar year 1981 in the amount of $443,100 and an addition to tax...

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