Donald DeCleene and Doris DeCleene v. Commissioner

115 T.C. No. 34

UNITED STATES TAX COURT DONALD DECLEENE AND DORIS DECLEENE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24459-97. Filed November 17, 2000. P had operated his business on the M Street property since 1977. In 1992, P purchased the unimproved L Drive property as replacement property. In September 1993, P and WLC, who wished to acquire M Street, agreed that M Street and unimproved L Drive were of equal value, $142,400; P quitclaimed title to L Drive to WLC for a deferred cash consideration of $142,400, to be paid at a second closing; WLC agreed to build a…