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PEABODY NATURAL RESOURCES CO. v. COMMISSIONER

Docket Nos. 20328-04, 6899-05.

126 T.C. 261 (2006)

126 T.C. No. 14

PEABODY NATURAL RESOURCES COMPANY, F.K.A. HANSON NATURAL RESOURCES COMPANY, CAVENHAM FOREST INDUSTRIES, INC., A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 8, 2006.

Attorney(s) appearing for the Case

Martin D. Ginsburg, Alan S. Kaden, and Richard A. Wolfe, for petitioner.

Alan M. Jacobson and Donald L. Wells, for respondent.

OPINION

GERBER, Chief Judge:

The parties filed motions for summary judgment1 under Rule 1212 at docket No. 20328-04 with respect to the issue of whether coal supply contracts that burdened coal mine property received by a partnership, as part of an exchange under section 1031, are like-kind property to the gold mining property transferred by the partnership.

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