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TERUYA BROS., LTD. & SUBS. v. COMMISSIONER

Docket No. 17955-03.

124 T.C. 45 (2005)

124 T.C. No. 4

TERUYA BROTHERS, LTD. & SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 9, 2005.

Attorney(s) appearing for the Case

Jonathan H. Steiner, William E. Bonano, and Stanley Y. Mukai, for petitioner.

Jonathan J. Ono, for respondent.

OPINION

THORNTON, Judge:

Respondent determined a $4,144,359 deficiency in petitioner's Federal income tax for its taxable year ending March 31, 1996. The issue for decision is whether petitioner is entitled to defer gains realized on certain like-kind exchanges under section 1031(a) or must recognize gains under section 1031(f), which provides special rules governing exchanges between related persons.1

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