Wakeham

914 F.2d 265 Unpublished Disposition NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Derrick WAKEHAM, Selma Wakeham Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. No. 88-6696. United States Court of Appeals, Ninth Circuit. Argued and Submitted Aug. 7, 1990. Decided Sept. 7, 1990. Before POOLE, CYNTHIA HOLCOMB HALL and DAVID R. THOMPSON, Circuit Judges. 1 MEMORANDUM * OVERVIEW 2 Selma and Derrick Wakeham appeal the district court's judgment that a series of real estate transactions they entered into did not qualify for tax exemption under 26 U.S.C. Sec. 1031 . BACKGROUND 3 On April 3, 1978, the Wakehams signed escrow instructions in an attempt to acquire a 50-unit apartment complex in Carlsbad, California. ("Carlsbad" property). The sellers of the Carlsbad unit were Da-De and Vivian Wei Chiang. The escrow instructions contemplated the possibility that the transaction would be part of a tax-free exchange. 4 On September 29, 1978 the escrow…