Need an outline written for this using IRA checkpoint and BNA, footnotes too please, will be using to write a memo 5 pages long.

Over 20 years ago, Celeste Margaret bought a multi-unit residential apartment building in La Jolla, California for $400,000. Over the past twenty years that the property has been rented, she has taken $150,000 of cost recovery on her individual income tax return. Although she never had an intention to sell the property, Sienna Claire approached her and offered to buy the building for $1,000,000. After careful thought and deliberation, Celeste accepted the offer and both parties executed a purchase and sale contract. That same day, Celeste told her friends about the sale and they warned her that she would end up paying 1/3 of her profit to the IRS. Not wanting to pay tax on the transaction, she googled about to sell my property how can I avoid paying tax" and found a website to a company called Real Estate Tax Experts and Consultants (RETEC) and hired them to help. They said that they can arrange to be middle-men and so long as Celeste bought another property, she could avoid paying tax, legally! So, on August 8, 2019, Celeste transferred the property to RETEC. Sienna Claire transferred $1,000,000 to RETEC. RETEC was to hold on the money until Sienna Claire found another property and was to use the money to buy that property. On September 4, 2019, Celeste found a vacant lot in Paris, France, to purchase and e-mailed RETEC that she was ready to move forward and buy the property and asked RETEC to get the funds ready to make the deal. She never heard anything from RETEC, but instead received a letter from the Bankruptcy Court on October 1, 2019 indicating that RETEC filed for bankruptcy. As of December 31, 2019, the bankruptcy proceedings are ongoing and Celeste has received none of the proceeds for her apartment building. It is not March 16, 2020, and time to file the 2019 tax return before the deadline. Celeste has no apartment building, no cash, and no vacant lot. How should Celeste report this transaction on her 2019 income tax return? Over 20 years ago, Celeste Margaret bought a multi-unit residential apartment building in La Jolla, California for $400,000. Over the past twenty years that the property has been rented, she has taken $150,000 of cost recovery on her individual income tax return. Although she never had an intention to sell the property, Sienna Claire approached her and offered to buy the building for $1,000,000. After careful thought and deliberation, Celeste accepted the offer and both parties executed a purchase and sale contract. That same day, Celeste told her friends about the sale and they warned her that she would end up paying 1/3 of her profit to the IRS. Not wanting to pay tax on the transaction, she googled about to sell my property how can I avoid paying tax" and found a website to a company called Real Estate Tax Experts and Consultants (RETEC) and hired them to help. They said that they can arrange to be middle-men and so long as Celeste bought another property, she could avoid paying tax, legally! So, on August 8, 2019, Celeste transferred the property to RETEC. Sienna Claire transferred $1,000,000 to RETEC. RETEC was to hold on the money until Sienna Claire found another property and was to use the money to buy that property. On September 4, 2019, Celeste found a vacant lot in Paris, France, to purchase and e-mailed RETEC that she was ready to move forward and buy the property and asked RETEC to get the funds ready to make the deal. She never heard anything from RETEC, but instead received a letter from the Bankruptcy Court on October 1, 2019 indicating that RETEC filed for bankruptcy. As of December 31, 2019, the bankruptcy proceedings are ongoing and Celeste has received none of the proceeds for her apartment building. It is not March 16, 2020, and time to file the 2019 tax return before the deadline. Celeste has no apartment building, no cash, and no vacant lot. How should Celeste report this transaction on her 2019 income tax return