North Central Rental & Leasing, LLC v. United States

SMITH, Circuit Judge.

The Internal Revenue Service (IRS) determined that North Central Rental & Leasing, LLC (“North Central”) had improperly ' claimed “nonrecognition treatment” 1 of gains from certain property exchanges. North Central filed suit against the United States, seeking a determination that its gains from the exchanges were, in fact, entitled to nonrecognition treatment. The district court 2 entered judgment in favor of the United States, and North Central appealed. We affirm.

I. Background

Butler Machinery Company (“Butler Machinery”) sells agricultural, mining, and construction…