Teruya Brothers Ltd., et al. v. Comr., 580 F.3d 1038 (9th Cir. 2009)

(court affirmed Tax Court's determination that plaintiff's exchange of properties does not qualify for deferral of gain under I.R.C. Sec. 1031; transactions were structured to avoid the related party restriction of I.R.C. Sec. 1031(f) via a series of transactions which also were designed to allow related parties to receive nonrecognition treatment while cashing out of investments using basis-shifting provisions of I.R.C. Sec. 1031; but a principal purpose of the overall transaction was tax avoidance and, thus, I.R.C. Sec. 1031(f)(4) violated).