In an appeal from a tax court's judgment denying nonrecognition treatment for the parties' like-kind real estate transactions, the order is affirmed where the exchanges did not qualify for nonrecognition treatment under 26 U.S.C. section 1031, because they took their peculiar structure for no apparent purpose except to avoid Section 1031.
Argued February 11, 2009
Filed September 8, 2009
Opinion by Judge Thomas
Jonathan S. Cohen, Attorney, Tax Division, Department of Justice, Washington, DC