United States Ninth Circuit
Teruya Bros. v. Comm'r. of Int'l. Rev., 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.
Appellate Information
- Argued 02/11/2009
- Decided 09/08/2009
- Published 09/08/2009
Judges
- THOMAS, Circuit Judge:, Before: STEPHEN REINHARDT, MELVIN BRUNETTI, and SIDNEY R. THOMAS, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Renee M.L. Yuen, Honolulu, Hawaii, for the petitioner-appellant.
- For Appellees:
- Nathan J. Hochman, Assistant Attorney General, Jonathan S. Cohen, Bridget M. Rowan, Attorneys, Tax Division, Department of Justice, Washington, D.C., for the respondent-appellee.