Docket No. 19161-91.

67 T.C.M. 2005 (1994)

T.C. Memo. 1994-27

Fred L. Fredericks v. Commissioner.

United States Tax Court.

Filed January 24, 1994.

Attorney(s) appearing for the Case

Charles P. Duffy, 5200 S.W. Macadam, Portland, Ore., Philip N. Jones, Peter J. Duffy, 1100 S.W. Sixth Ave., Portland, Ore., for the petitioner. Shirley M. Francis, for the respondent.

Memorandum Findings of Fact and Opinion

RUWE, Judge.

Respondent determined a deficiency of $1,033,941.00 in petitioner's Federal income tax for 1983 and an addition to tax of $258,485.25 pursuant to section 6661.1

The issues for decision are: (1) Whether petitioner exchanged real property within the meaning of section 1031(a); (2) if so, whether petitioner must recognize...

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