MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency of $33,242 in petitioner's Federal income tax for 1990.
The issue for decision is whether petitioner may defer recognition of gain realized on the sale of two properties pursuant to section 1031(a). We hold that he may not because he failed to establish that he identified replacement property within 45 days after he transferred the relinquished properties.<...
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