Yates v. Comr., T.C. Memo. 2013-28

(petitioners, married couple, received a bed and breakfast as boot in a muti-party like-kind exchange; while petitioners claimed that they intended to use the property as business property, they failed to produce evidence of business use instead using the property as a personal residence; petitioners could, however, to use FMV allocations utilized for purpose of exchange because parties were in adverse positions and IRS did not adequately refute allocations set forth in agreement).