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1. Tax Court finds that vacation home held primarily for personal use not consistent with “held for investment” intent under Section 1031.

Click here for case of Barry E. Moore et ux. v. Commissioner; T.C. Memo. 2007-134; No. 11002-03, May 30, 2007. 


2. Tax relief (extension of 45 and 180 day timeframes) in disaster situations. 

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3. IRS LTR 200724007 does not consider Qualified Intermediary (QI) a disqualified person when less than 10% owned by disqualified persons or should QI pay a commission to a disqualified person such as an accountant or realtor. 

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4. IRS PLR 200807005 approves of “Single Member Limited Partnership” as a disregarded entity.

In PLR 200807005, the IRS explicitly approved an arrangement where the taxpayer proposed to acquire replacement property in a like-kind exchange by acquiring 100% of the interest in a limited partnership that owned the replacement property.

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Andrew W. Gustafson, CES®
Managing Member
Atlas 1031 Exchange, LLC
Toll Free: 866.521.1031  |  EFax: 850.201.6911
Dallas: 214.523.9067  |  Destin: 850.837.1031  |  Houston: 713.821.1776
Email:
andgus@atlas1031.com

Atlas 1031 Exchange, LLC is a Qualified Intermediary and does not provide advice regarding specific tax consequences of IRC 1031 tax deferred exchanges.  Investors are encouraged to seek the counsel of their attorney and accountant.


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