Von Muff v. Commissioner

1983 T.C. Memo. 514, 46 T.C.M. 1185, 1983 Tax Ct. Memo LEXIS 286
CourtUnited States Tax Court
DecidedAugust 22, 1983
DocketDocket No. 4751-81.
StatusUnpublished

This text of 1983 T.C. Memo. 514 (Von Muff v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Von Muff v. Commissioner, 1983 T.C. Memo. 514, 46 T.C.M. 1185, 1983 Tax Ct. Memo LEXIS 286 (tax 1983).

Opinion

KARL G. VON MUFF and GERTRUD L. VON MUFF, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Von Muff v. Commissioner
Docket No. 4751-81.
United States Tax Court
T.C. Memo 1983-514; 1983 Tax Ct. Memo LEXIS 286; 46 T.C.M. (CCH) 1185; T.C.M. (RIA) 83514;
August 22, 1983.
Karl G. Von Muff, pro se.
David P. Fuller, for the respondent.

WILBUR

MEMORANDUM FINDINGS OF FACT AND OPINION

WILBUR, Judge: Respondent determined a deficiency in petitioners' Federal income taxes for the taxable year 1977 of $5,984.36. The issues for decision are (1) whether the sales of two rental properties followed by purchases of two other rental properties constitute nontaxable exchanges under section 1031, 1 and (2) whether certain loan origination fees and escrow costs paid in connection with the financing and acquisition of rental properties are deductible.

All the facts have been stipulated and are so found.The stipulation of facts and the exhibits attached thereto are incorporated herein by reference.

Petitioners Karl G. Von Muff and Gertrud*288 L. Von Muff, husband and wife, resided in Bell, California at the time the petition herein was filed. The filed a timely joint Federal income tax return for the taxable year 1977 with the Internal Revenue Service Center in Fresno, California.

Facts and Opinion re: Issue 1

In early 1977, petitioners owned various rental properties in California. In June 1977, petitioners sold rental property located at 3419 Bell to Gonzalo and Ana Gonzales. Shortly thereafter, petitioners applied the proceeds from this sale towards their purchase, from Mrs. Haydee Cook, of a rental property located at 216 Cypress, Long Beach, California.

In November 1977, petitioners sold rental property at 3425 Bell to Alvaro and Nora Gutierrez. Shortly thereafter, petitioners applied the proceeds from this sale towards their purchase, from Fred Wiseman, of a rental property located at 515 Poplar, Long Beach, California.

Petitioners contend that the transactions described above constitute like-kind exchanges under section 1031 and therefore do not give rise to taxable gain. We disagree.

An essential prerequisite*289 for nonrecognition treatment under section 1031 is that there be an "exchange" of properties. A sale of one property for cash followed by a separate investment of the proceeds in "like-kind" property simply does not qualify as an exchange. Bell Lines, Inc. v. United States,480 F.2d 710, 713-714 (4th Cir. 1973); Coastal Terminals, Inc. v. United States,320 F.2d 333, 337 (4th Cir. 1963); Barker v. Commissioner,74 T.C. 555, 560-561 (1980). As was stated in Coastal Terminals, Inc. v. United States,320 F.2d at 337:

The purpose of Section 1031(a), as shown by its legislative history, is to defer recognition of gain or loss when a direct exchange of property between the taxpayer and another party takes place; a sale for cash does not qualify as a nontaxable exchange even though the cash is immediately reinvested in like property.

Petitioners alternatively contend that section 1031 violates the equal protection clause of the Constitution in that it allows similarly situated taxpayers to avoid the capital gains tax by merely arranging simultaneous exchange escrows. Unfortunately for petitioner, this is an area*290 where the form utilized in structuring a "like-kind" transaction is crucial. "[T]he conceptual distinction between an exchange qualifying for section 1031 on the one hand and a sale and reinvestment on the other hand is largely one of form." Barker v. Commissioner,supra at 566.

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Related

Coastal Terminals, Inc. v. United States
320 F.2d 333 (Fourth Circuit, 1963)
Bell Lines, Inc. v. United States
480 F.2d 710 (Fourth Circuit, 1973)
Enoch v. Commissioner
57 T.C. 781 (U.S. Tax Court, 1972)
Biggs v. Commissioner
69 T.C. 905 (U.S. Tax Court, 1978)
Brauer v. Commissioner
74 T.C. 1134 (U.S. Tax Court, 1980)
Barker v. Commissioner
74 T.C. 555 (U.S. Tax Court, 1980)
Goodwin v. Commissioner
75 T.C. 424 (U.S. Tax Court, 1980)

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1983 T.C. Memo. 514, 46 T.C.M. 1185, 1983 Tax Ct. Memo LEXIS 286, Counsel Stack Legal Research, https://law.counselstack.com/opinion/von-muff-v-commissioner-tax-1983.