Mr. Bryan Olgivie owned an indoor roller-skating rink as a sole proprietorship. On April 9, a flood completely destroyed the rink. Mr. Olgivie’s adjusted basis in the rink was $833,400. On May 15, he received a check for $1.1 million from his insurance company in complete settlement of his damage claim. Mr. Olgivie is planning to use the entire insurance settlement to purchase 100 percent of the outstanding stock of IceMagic Inc., a corporation that owns an indoor ice-skating rink. Can he defer the recognition of gain on the involuntary conversion of his roller-skating rink by purchasing the IceMagic stock?
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