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Tax Court upholds non–safe-harbor reverselike-kind exchange Logo aicpa

  Laura Michaels, CPA, and Patricia Brandstetter,... |   Free |   AICPA |   01 May 2017 |   Tax Adviser Magazine

The Tax Court's decision in Estate of Bartell, 147 T.C. No. 5 (2016), alleviates some of the uncertainty that taxpayers and practitioners face when structuring a reverse like-kind exchange intended to qualify for nonrecognition treatment under Sec. 1031. Learn more about why the Tax Court rejected the IRS's position that a third-party "exchange facilitator" the taxpayer engaged to take legal title to the replacement property was required to assume the benefits and burdens of ownership of the property to facilitate a valid Sec. 1031 exchange. 

Topics covered:
  • Tax: Technical: S corporation income taxation: Allocations of profits & losses, Intermediate