Teruya Bros. v. Comm'r. of Int'l. Rev., No. 05-73779

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.

Read Teruya Bros. v. Comm'r. of Int'l. Rev., No. 05-73779

Appellate Information

Argued February 11, 2009

Filed September 8, 2009

Judges

Opinion by Judge Thomas

Counsel

For Petitioner:

Renee M.L. Yuen, Honolulu, HI

For Respondent:

Jonathan S. Cohen, Attorney, Tax Division, Department of Justice, Washington, DC

Bridget M. Rowan, Attorney, Tax Division, Department of Justice, Washington, DC