John M. Rogers and John M. Rogers, of the Estate of Gladys B. Rogers, Deceased v. Commissioner of Internal Revenue

This is a petition for a review of the decision of the Tax Court (44 T.C. 126). This Court has jurisdiction (26 U.S.C. § 7482). The Tax Court held the Petitioners’ transfer of a parcel of realty and the contemporaneous acquisition of another parcel of realty was not a tax-free exchange within the purview of § 1031 of the Internal Revenue Code of 1954 (26 U.S.C. § 1031).

The findings of the Tax Court are fully supported by the record. We have carefully considered Petitioners’ specifications of error and arguments and find them without merit. We affirm the well-reasoned opinion of the Tax Court.…